United States v. Culbert

Summary

The Supreme Court held that the Hobbs Act does not require the government to prove that a defendant's conduct constituted additional, undefined "racketeering" beyond the statute's express elements. The Court relied on the statutory text, legislative history, and constitutional-avoidance concerns regarding an undefined racketeering requirement. It reversed the Ninth Circuit's judgment.

Holdings

1. The Hobbs Act does not require the government to prove that conduct otherwise within the statute's express terms also constitutes racketeering.
2. The rule of lenity and the federalism canon do not justify adding a racketeering requirement where Congress has clearly conveyed the statute's purpose and meaning.

Questions Presented

1. Whether the Hobbs Act requires the government to prove an additional, unstated element that the defendant's conduct constituted racketeering.
2. Whether the rule of lenity or federalism canon justified limiting the Hobbs Act's coverage to racketeering conduct.

Disposition

reversed