Salahuddin v. United States (U.S. Supreme Court)

The Hobbs Act imposes criminal penalties for anyone who “obstructs, delays, or affects commerce or the movement of any article or commodity in commerce, by robbery or extortion or attempts or conspires so to do,” U.S.C. § 1951(a), and a broad definition of “extortion” applies the Act to various types of political corruption. In conjunction with the Yale Supreme Court Clinic, we filed a petition for certiorari on the question of whether a conspiracy charge under the Hobbs Act requires the government to show that a defendant committed an “overt act” in furtherance of the alleged conspiracy. In doing so, we sought review of a Third Circuit decision that upheld a conviction without proof of an overt act and added to a deep conflict among the circuit courts over the overt-act requirement.