Conspiracy to extort outsiders
Ocasio v. United States
In brief
The Supreme Court upheld the lower court's ruling: Ocasio could be convicted of Hobbs Act conspiracy based on an agreement with the shop owner to obtain property through misuse of public office.
- Where it stands
- Decided
Decided 5-3 · May 2, 2016 · Opinion by Justice Alito
- What it’s about
- Samuel Ocasio, a Baltimore police officer, challenged his conspiracy conviction over payments from an auto-repair shop for referrals, arguing that the agreement had to target someone outside the conspiracy.
- Who it affects
- The ruling allows a conspiracy conviction under the federal Hobbs Act extortion law based on an agreement with the property's owner to obtain property through misuse of public office.
Summary: written with AI from the case record.
What it's about
The Supreme Court upheld the Fourth Circuit’s ruling, deciding that he could be convicted based on an agreement with a property owner to obtain money by misusing public office.
The indictment alleged that Ocasio and other Baltimore officers referred crash victims to an auto-repair shop, whose owners paid Ocasio $150 to $300 for each referral.
The Hobbs Act is a federal law against extortion, including obtaining property through misuse of public office.
Question presented
Does a conspiracy to commit extortion require that the conspirators agree to extort money or property from a third party outside of the conspiracy?
What the Court decided
Holding
A defendant may be convicted of conspiring to violate the Hobbs Act based on proof that he reached an agreement with the owner of the property in question to obtain that property under color of official right. 750 F. 3d 399, affirmed.
- Result
- Affirmed
The vote
- Joined the judgment
- Concurred in a separate opinion
- Dissented
- Wrote an opinion
- Concurring · 1agreed with the result, wrote separately
- Breyerwrote separately
From the opinions
“If a group of conspirators sets out to extort “another” person, we ordinarily think that they are proposing to extort money or property from a victim outside their group, not one of themselves.”
What's next
The Fourth Circuit's ruling stands, leaving Ocasio's conspiracy conviction in place.
Documents
Opinions
Docket activity
New analysis added
AI analysis generated: Case Briefing
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AI analysis generated: Impact Analysis
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AI analysis generated: Decision Record
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Case data updated: question_presented, extraction_metadata
Opinion added: Ocasio
More questions
- What concern did Justice Breyer raise?
- He questioned whether the Hobbs Act should treat extortion as the rough equivalent of taking a bribe.
Sources
Primary materials plus reporting. Best-effort analysis: this explainer relies on a mix of primary materials and trusted secondary sources. Official filings and opinions remain authoritative.