Ocasio v. United States: Why the Hobbs Act Punishes Co-Conspirator Extortion

Abstract

The issue of police corruption is a dynamic topic of public dialogue. In Ocasio v. United States, the issue before the United States Supreme Court was whether the conduct of Defendant, a former member of the Baltimore City Police Department, was contemplated by the Hobbs Act. The Defendant was involved as a co-conspirator in a kickback scheme, for which he was convicted under Section 1951(b)(2) under the Hobbs Act. This Article argues that the term "another" in Section 1951(b)(2) contemplates Defendant's role as a co-conspirator; therefore, the Court should uphold Defendant's conviction. This Article argues that the text, legislative history, and the public policy underlying the Hobbs Act support this construction of the Hobbs Act. Further, this Article explores the important role that the Hobbs Act serves in fighting police corruption. This Article was published before the Supreme Court's disposition, and should be cited as follows: Joshua T. Carback, Note, Joshua T. Carback, Ocasio v. United States: Why the Hobbs Act Punishes Co-Conspirator Extortion, 75 Md. L. Rev. Endnotes (2016).

Keywords: police corruption, extortion, statutory interpretation, criminal law, Hobbs Act

JEL Classification: K14