Tickets, Luggage, and Meals

A farm-industry trade association gave a cabinet secretary gifts worth about six thousand dollars: tickets to a tennis tournament, luggage, meals, and a framed print with a crystal bowl. At the time, the association had two important matters pending in his department. But prosecutors did not claim any gift was tied to any particular decision. The association was charged with giving an illegal gratuity. That law forbids giving anything of value to an official for or because of any official act. Is a gift given simply because of the official's position enough?