Broadening the Scope of Conspiracy
The U.S. Supreme Court in Ocasio v. United States nudged the
breadth of conspiracy law even further out in the context of the Hobbs Act. That act makes it unlawful to
commit extortion, which means the "obtaining of property from
another with his consent, induced by wrongful use of actual or
threatened force, violence, or fear, or under color of official
right." Here, Samuel Ocasio, a former police officer,
participated in a kickback scheme whereby he and other officers
would send accident victims to a certain auto-body shop in exchange
for payment of a few hundred dollars per customer. Ocasio was
charged, along with the owners of the auto-body shop, with
conspiracy to violate the Hobbs Act, under 18 U.S.C. 371. Ocasio argued he did not
conspire to obtain property "from another" because the
conspirators obtained property from one of their own, i.e., the
owners of the shop. Ocasio was convicted, and the court of appeals
rejected his
