 Charles Ruff referred to " the prosecution of local officials for acts of public corruption " as " perhaps the most sensitive area of federal @-@ state cooperation . " Several other commentators have expressed federalism concerns about such prosecutions . Others have disagreed . But , as Whitaker notes , " Congress and the courts have not raised potential federalism concerns and , in fact , appear to approve of increased use of federal law to prosecute low @-@ level bribery at the state and local levels . " According to Professor John C. Coffee , " [ a ] lthough this prophesy that the Supreme Court will curb the federal fraud statutes may yet prove accurate , that is not the direction in which the lower federal courts have been moving . " 
