All those whose interests are to be affected by legislation, may, both morally and legally, for the protection or advancement of their interests, use all means of persuasion which do not come too near to bribery or corruption; but the promise of any personal advantage to a legislator is open to this objection, and therefore void. (h)1 And a contract tending to corrupt appointment * to office, even by a private corporation, is, for a similar reason, void. (i) The cases are somewhat numerous which show that contracts which have a tendency to introduce corruption either in the election or the action of persons holding office of any kind cannot be enforced. (ii)

(h) See Clippinger v. Hepbaugh, 6 Watte & S. 316; Wood v. McCann, 6 Dana, 366; Coppock v. Bower, 4 M. & W. 361; Hatzfleld v. Gulden, 7 Watts, 152; Norman v. Cole, 3 Esp. 253; Fuller v. Dame, 18 Pick. 472; Brigg v. Washborne, 1 Aik. 264; Garlick v. Ward, 5 Halst. 87; Harris v. Roof, 10 Barb. 489. This subject is very fully discussed in the late case of Marshall v. Baltimore & Ohio Railroad Company, 16 How. 314 It is there held, that a contract is void, as against public policy, and can have no standing in court, by which one party stipulates to employ a number of secret agents in order to obtain the passage of a particular law by the legislature of a State, and the other party promises to pay a large sum of money in case the law should pass. Held, also, that the contract was void, if, when it was made, the parties agreed to conceal from the members of the legislature the fact, that the one party was the agent of the other, and was to receive a compensation for his services, in case of the passage of the law. And further, if there was no agreement to that effect, there can be no recovery upon the contract, if in fact the agent did conceal from the members of the legislature, that he was an agent who was to receive compensation for his services, in case of the passage of the law. Mr. Justice Grier, in delivering his opinion, said: "Influences secretly urged under false and covert pretences must necessarily operate deleteriously on legislative action, whether it be employed to obtain the passage of private or public acts. Bribes, in the shape of high contingent compensation, must necessarily lead to the use of improper means and the exercise of undue influence. Their necessary consequence is, the demoralization of the agent who covenants for them; he is soon brought to believe that any means which will produce so beneficial a result to himself are 'proper means;' and that a share of these profits may have the same effect of quickening the perceptions and warming the zeal of influential or 'careless' members in favor of his bill. The use of such means and such agents will have the effect to subject the State governments to the combined capital of wealthy corporations, and produce universal corruption, commencing with the representative and ending with the elector. Speculators in legislation, public and private, a compact corps of venal solicitors, vending their secret influences, will invest the capital of the Union and of every State, till corruption shall become the normal condition of the body politic, and it will be said of us as of Rome - 'omne Romos venale.' "

(i) Davison v. Seymour, 1 Bosw. 88.

(ii) Mills v. Mills. 40 N. Y. 543; Bowman v. Coffroth, 59 Penn. St. 19; Weld v. Lancaster, 56 Me. 453; Martin v. Wade, 37 Cal. 168.

1 See also Trist v. Child, 21 Wall. 441.