employment. Id. at 443. The patronage scheme was charged under Section 601, and also under Sections 666, 1341, 1346, and 1952. All four prosecutive theories went to the jury, which convicted the defendants on the Sections 601 and 666 counts. In the defendants’ first appeal, the Third Circuit reversed the Section 666 convictions, holding that Congress did not intend this statute to apply to the extortion of political activity rather than money. Id. at 445. In a subsequent appeal, the Third Circuit held that Section 601 does not apply if there are no express threats or specific promises made to induce political services from public employees. United States v. Cicco, 10 F.3d 980, 985 (3d Cir. 1993). (b) Promise of appointment by candidate: 18 U.S.C. § 599 This statute prohibits a candidate for federal office from promising appointments “to any public or private position or employment” in return for “support in his candidacy.” It is one of the few federal criminal laws specifically addressing campaign-related activity by candidates. It is a class statute that applies only to misconduct by federal candidates. Willful violations are two-year felonies; non-willful violations are misdemeanors. Section 599 has potential application when one candidate attempts to secure an opponent’s withdrawal, or to elicit the opponent’s endorsement, by offering the opponent a public or private job. See also 18 U.S.C. § 600, discussed above. It also applies to offers of jobs by federal candidates to others to secure endorsements. While Section 599 does not reach offers or payments of money to secure withdrawal or endorsements, if the payment was not reported accurately, such matters may be prosecutable as a reporting violation of FECA under 52 U.S.C. §§ 30104(b) and 30109(d). 110