Texas Codes

Tex. Penal Code § 32.43 (2026)

Commercial Bribery

✓ current as of May 2026
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Sec. 32.43. COMMERCIAL BRIBERY. (a) For purposes of this section:

(1) "Beneficiary" means a person for whom a fiduciary is acting.

(2) "Fiduciary" means:

(A) an agent or employee;

(B) a trustee, guardian, custodian, administrator, executor, conservator, receiver, or similar fiduciary;

(C) a lawyer, physician, accountant, appraiser, or other professional advisor; or

(D) an officer, director, partner, manager, or other participant in the direction of the affairs of a corporation or association.

(b) A person who is a fiduciary commits an offense if, without the consent of his beneficiary, he intentionally or knowingly solicits, accepts, or agrees to accept any benefit from another person on agreement or understanding that the benefit will influence the conduct of the fiduciary in relation to the affairs of his beneficiary.

(c) A person commits an offense if he offers, confers, or agrees to confer any benefit the acceptance of which is an offense under Subsection (b).

(d) An offense under this section is a state jail felony.

(e) In lieu of a fine that is authorized by Subsection (d), and in addition to the imprisonment that is authorized by that subsection, if the court finds that an individual who is a fiduciary gained a benefit through the commission of an offense under Subsection (b), the court may sentence the individual to pay a fine in an amount fixed by the court, not to exceed double the value of the benefit gained. This subsection does not affect the application of Section 12.51(c) to an offense under this section committed by a corporation, an association, a limited liability company, or another business entity, as defined by Section 7.21.

Acts 1973, 63rd Leg., p. 883, ch. 399, Sec. 1, eff. Jan. 1, 1974. Amended by Acts 1983, 68th Leg., p. 1942, ch. 357, Sec. 1, eff. Sept. 1, 1983; Acts 1993, 73rd Leg., ch. 900, Sec. 1.01, eff. Sept. 1, 1994.

Amended by:

Acts 2019, 86th Leg., R.S., Ch. 112 (S.B. 1258), Sec. 5, eff. September 1, 2019.

Notes of Decisions
Cited in 34 cases (3 in the last 5 years), 1979–2024 · leading case: United States v. Shah, 95 F.4th 328 (5th Cir. 2024).
United States v. Shah, 95 F.4th 328 (5th Cir. 2024). · cites it 7× “001(a) (criminalizing accepting money for patient referrals); Tex. Penal Code § 32.43 (same); see also, e.”
United States v. Shah, 84 F.4th 190 (5th Cir. 2023). · cites it 7× “001(a) (criminalizing accepting money for patient referrals); Tex. Penal Code § 32.43 (same); see also, e.”
Comm'n for Lawyer Discipline v. Benton, 980 S.W.2d 425 (Tex. 1998). · cites it 2× “, TEX. PEN.CODE § 32.43; id. § 36.04, and other courts have upheld them against vagueness challenges.”
Perrin v. United States, 444 U.S. 37 (1979). “§§ 39-821 , 39-824 to 39-826 (1975) (common carriers, sports); Tex. Penal Code Ann. §§32.43 , 32.44 (1974) (attorneys, sports); Wash.”
Cont'l 332 Fund, LLC v. Albertelli, 317 F. Supp. 3d 1124 (M.D. Fla. 2018). “§ 18-5-401 ; see also Tex. Penal Code § 32.43 ; Minn. Stat. § 609.”
Greenberg Traurig of New York, P.C. v. Moody, 161 S.W.3d 56 (Tex. App. 2005). “Tex Pen.Code Ann. § 32.43 (Vernon 2003). 8 .”
McGowan v. State, 938 S.W.2d 732 (Tex. App. 1997). · cites it 2× “A jury convicted appellant, Matthew McGowan, of two counts of commercial bribery, TEX.PENAL CODE ANN. § 32.43(b) (Vernon 1989), [1] and one count of theft of trade secrets.”
Ex Parte Mattox, 683 S.W.2d 93 (Tex. App. 1984). · cites it 2× “[1] The indictments allege the offense of commercial bribery, Tex.Pen. Code Ann. § 32.43(c) (1974), [2] and are based on the same alleged incident.”
In Re Enron Corp. Sec., Derivative & Erisa Lit., 761 F. Supp. 2d 504 (S.D. Tex. 2011). “008(c) because each Defendant violated and/or conspired with Enron to violate Texas Penal Code §§ 32.43 (commercial bribery) and/or 32.”
LeBlanc v. Lange, 365 S.W.3d 70 (Tex. App. 2011). “” Tex. Penal Code Ann. § 32.43 (b) (Vernon 2011).”
John Zervas v. D.L. Faulkner, Spencer Blain & Jane Nix, 861 F.2d 823 (5th Cir. 1988). “§ 1341 or § 1343) or commercial bribery (contrary to Tex. Penal Code Ann. § 32.43 ) amounting to a pattern of racketeering activity (Question 1), that through the pattern of racketeering activity defendants each conducted or participated in the conduct of an enterprise (Question…”
United States v. Louis Parise, Jr., 159 F.3d 790 (3rd Cir. 1998). “Codified Laws § 22-43-1 ; Texas, see Tex. Penal Code § 32.43; Utah, see Utah Code Ann.”
— Tex. Penal Code § 32.43(a) — 1 case
in Re Jinsun LLC (Tex. App. 2015).
— Tex. Penal Code § 32.43(a)(2)(B) — 1 case
McCay, Mark (Tex. 2015).
— Tex. Penal Code § 32.43(b) — 7 cases
McGowan v. State, 938 S.W.2d 732 (Tex. App. 1997). “A jury convicted appellant, Matthew McGowan, of two counts of commercial bribery, TEX.PENAL CODE ANN. § 32.43(b) (Vernon 1989), [1] and one count of theft of trade secrets.”
Adegbenro v. State, 36 S.W.3d 658 (Tex. App. 2001).
— Tex. Penal Code § 32.43(c) — 4 cases
United States v. Shah, 95 F.4th 328 (5th Cir. 2024). “001(a) (criminalizing accepting money for patient referrals); Tex. Penal Code § 32.43 (same); see also, e.”
Ex Parte Mattox, 683 S.W.2d 93 (Tex. App. 1984). “[1] The indictments allege the offense of commercial bribery, Tex.Pen. Code Ann. § 32.43(c) (1974), [2] and are based on the same alleged incident.”
United States v. Shah, 84 F.4th 190 (5th Cir. 2023). “001(a) (criminalizing accepting money for patient referrals); Tex. Penal Code § 32.43 (same); see also, e.”
in Re Jinsun LLC (Tex. App. 2015).
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