Page 36 of 42 103 Minn. L. Rev. 844, *913 use). But see Mark S. Gaioni, Federal Anticorruption Law in the State and Local Context: Defining the Scope of 18 U.S.C. § 666, 46 Colum. JL. & Soc. Probs. 207, 237-45 (2012) (arguing for broad interpretation of § 666 to cover state and local officials). 163 See, e.g., /8 U.S.C. § 1346 (2012) (criminalizing "honest services" fraud). The statute was enacted in 1988 in response to the Supreme Court's 1987 decision in United States v. McNally, which held that 78 U.S.C. § 1341 did not cover "honest services" fraud. Gaioni, supra note 162, at 243 n.192. 164 See, e.g., Perrin, 444 U.S. at 50 (finding that section 1952 reflects congressional intent “to alter the federal-state balance in order to reinforce state law enforcement"). 165 See, e.g., 18 U.S.C. § 1952 (2012) (prohibiting interstate travel for "unlawful activity," which can be made unlawful by state law); Perrin 444 U.S. at 50 ("In defining "unlawful activity! [in JS U.S.C. § 1952], Congress has clearly stated its intention to include violations of state as well as federal bribery law."); United States v. Welch, 327 F.3d 1081, 1092-1103 (10th Cir. 2003) (reinstating an indictment and holding that Utah law serves as predicate to define violations of /8 U.S.C. § 1952). 166 See Kim, supra note 149; Dripps, supra note 149, at 3 (noting that sexual assaults in federal law are confined to very limited contexts, such as human trafficking). 167 See Kim, supra note 149. 168 See Lynching in America: Confronting the Legacy of Racial Terror, Equal Just. Initiative, hitps://ynchinginamerica.eji.org/report (last visited Oct. 30, 2018) ("Of all lynchings committed after 1900, only 1 percent resulted in a lyncher being convicted of a criminal offense" (citing Paula J. Giddings, Ida: A Sword Among Lions 473-74 (2008))). Data on prosecutorial charging decisions is harder to come by, but clearance rates for homicides - meaning the percentage of cases police resolve, usually by arrest - are