	Introduction

One defendant robbed local drug dealers. In the case of the Hobbs Act where Congress sought to exercise its Commerce Clause powers to the fullest, the courts have held that the impact on commerce in an individual case may be minimal, even de minimis . Aiding and Abetting, Attempt, and Conspiracy

The Hobbs Act explicitly condemns not just robbery, but also attempts to rob and conspiracies to rob. § 2, it also condemns aiding and abetting a Hobbs Act robbery. Sentencing

Hobbs Act robbery offenses are punishable by imprisonment for not more than 20 years. In addition, a defendant whose violation involved a firearm may have committed a second, separate offense under 18 U.S.C. § 924(c). RICO violations are punishable by imprisonment for not more than 20 years. Violations of section 1956 carry a penalty of imprisonment for not more than 20 years. Extortion

Hobbs Act extortion comes in two forms. Regardless of form, Hobbs Act extortion and Hobbs Act robbery share many of the same elements as is obvious from a display of its components:
(1)Whoever 
(2) in any way or degree 
(3) (a) obstructs, 
(b) delays, or 
(c) affects 
(4) (a) commerce or 
(b) the movement of any article or commodity in commerce, 
(5)(a) by extortion, i.e .,
(i) [knowing and willful]
(ii) obtaining the property of another
(iii) with his consent
(iv) (A) induced by wrongful use of actual or threatened 
(I) force, or
(II) violence, or 
(III) fear of injury, or 
(B) under color of official right
(b) attempts or 
(c) conspires so to do, or 
(d) commits or threatens physical violence to any person or property in furtherance of a plan or purpose to do anything in violation of this section
shall be fined under this title or imprisoned not more than twenty years, or both 

		Whoever

Again, the term "whoever" in federal law refers to an individual as well as to legal entities such as corporations, labor organizations, and unincorporated associations. In Enmons , the Supreme Court explained that the word "wrongful" as used in the Hobbs Act extortion provision refers to the use of force, violence, or fear to obtain property to which the extortionist has no lawful claim. Color of Official Right

Hobbs Act extortion under color of official right occurs when a "public official has obtained a payment to which he is not entitled, knowing that the payment was made in return for official acts." It envisions a corrupt this-for-that ( quid pro quo ). Aiding and Abetting, Attempt, and Conspiracy

As is true of Hobbs Act robbery, section 1951 proscribes obstructing commerce by means of extortion, and attempting or conspiring to do so. Sentencing

Hobbs Act extortion, attempts, and conspiracies are all punishable by imprisonment for not more than 20 years. Hobbs Act extortion, however, qualifies as a predicate offense under RICO, the money laundering statutes, and the Travel Act.
The Hobbs Act proscribes obstructing commerce by means of robbery or extortion or attempting or conspiring to do so. The Act applies to individuals and legal entities alike. It permits prosecutions, although the impact on commerce may be minimal. It condemns the robbery—knowingly taking the property of another by force or threat—of drug dealers, mom-and-pop markets, and multinational corporations.
Attempted Hobbs Act robbery consists of an intent to rob, coupled with a substantial step toward that objective; conspiracy, a scheme of two or more to rob or extort; and accomplice liability, aiding and abetting a Hobbs Act violation of another.
Hobbs Act robbery, punishable by imprisonment for not more than 20 years, often occurs in confluence with the use of a firearm during and in furtherance of its commission, a fact that triggers the mandatory minimum sentences authorized in 18 U.S.C. § 924(c). The facts present in a Hobbs Act robbery case may also implicate violations of (1) the federal racketeering statute punishable by imprisonment for not more than 20 years and (2) the federal money laundering statutes, likewise punishable by imprisonment for not more than 20 years.
Hobbs Act extortion comes in two forms. One is akin to robbery, the other to bribery. Neither requires but a minimal impact on commerce. Both view individuals as well as organizations as potential defendants. As a robbery look-alike, it outlaws the wrongful use of force or fear to induce another to surrender property to which the aggressor has no lawful claim. As a bribery look-alike, it outlaws corrupt quid pro quos, i.e., a public official obtaining a payment, to which he is not entitled, in anticipation of the performance of an official act. The proscriptions also apply to attempt or conspiracy to commit either variety of Hobbs Act extortion and may implicate accomplice liability (aiding and abetting) as well.
Hobbs Act extortion in either form is punishable by imprisonment for not more than 20 years. Moreover, in addition to the racketeering and money laundering, the facts in a Hobbs Act extortion case may also implicate the Travel Act, which condemns interstate travel to promote an extortion or bribery scheme and that carries a penalty of imprisonment for not more than five years.