 Professor Adam Kurland has proposed the Guarantee Clause of Article Four of the United States Constitution — which provides that " [ t ] he United States shall guarantee to every State in the Union a Republican Form of Government " — as a constitutional basis for corruption statutes as applied to state and local officials . Professor John C. Coffee argues that " there is a more modest role for the Guarantee Clause " in distinguishing between public and private corruption under the same statutes . 
