Page 25 of 42 103 Minn. L. Rev. 844, *891 enforcement can learn of misconduct done mostly in secret, political or personal incentives for enforcement officials that discourage zealous enforcement can exist for enforcement officials in the same jurisdiction - perhaps enmeshed in the same political networks. In short, underenforcement in this realm follows more from favoritism toward offenders than the biases against victim groups or types of offenses. "Corruption" is a notoriously hard concept to define, '*° but that difficulty is actually somewhat useful for present purposes. Some of what constitutes public corruption is relatively clearly [*892] defined in positive law. Easy cases involve straightforward property theft or embezzlement, quid pro quo bribery, and extortion. !*! Statutes also make clear at least some cases of illegal gratuities and breaches of regulations that govern activities such as campaign finance. '** More ambiguous or marginal cases of alleged corruption, however, illustrate the federal government's ambitious commitment to enforcing broad interpretations of federal anti-corruption laws to conduct of state and local officials. That enforcement track record demonstrates the strong commitment to enforcement redundancy in this area. States have their own regulatory strategies to address government corruption, although independent assessments do not judge them to be particularly successful. '°? The federal government seems to share that view. The Justice Department created a Public Integrity Section within the Criminal Division in 1976, !°4 and in the four decades since, federal prosecutors have [*893] aggressively prosecuted conduct of state and local officials that it determines breaches federal anti-corruption statutes. 'S For the past two decades, federal anti-corruption prosecutions of state and local officials typically average 350-400 per year. 156 Combatting "public corruption" is a top priority for the Federal Bureau of Investigation, on pa