The white collar crimes on the Supreme Court's 2015 docket consist of three Hobbs Act cases and one on computer fraud. The Hobbs Act outlaws robbery and extortion when committed in a manner which "in any way or degree" obstructs interstate commerce. One of the cases before the Court, Taylor v. United States , involved the robbery of suspected drug dealers. The second, Ocasio v. United States , consisted of a kickback conspiracy between traffic cops and body shop owners. The third, McDonnell v. United States , involved a local drug manufacturer who showered a state governor and his wife with gifts in an apparent attempt to use the governor's office as a bully pulpit for one of his products. H olding : " In order to obtain a conviction under the Hobbs Act for the robbery or attempted robbery of a drug dealer, the Government need not show that the drugs that a defendant stole or attempted to steal either traveled or were destined for transport across state lines. Rather, to satisfy the Act's commerce element, it is enough that a defendant knowingly stole or attempted to steal drugs or drug proceeds, for, as a matter of law, the market for illegal drugs is commerce over which the United States has jurisdiction. And it makes no difference ... that any actual or threatened effect on commerce in a particular case is minimal . " The Court, in a 7-1 decision written by Justice Alito, made it clear that Taylor was more about drugs than about the Hobbs Act: "Our holding today is limited to cases in which the defendant targets drug dealers for the purpose of stealing drugs or drug proceeds. We do not resolve what the government must prove to establish Hobbs Act robbery where some other type of business or victim is targeted." Taylor, the petitioner in the case, was a member of a gang of inept home invaders who sought to rob drug dealers of their cash and drugs. The two robberies for which he was convicted netted the group a total of $40 in cash, three cell phones, a marijuana cigarette, and some jewelry. Federal prosecutors charged Taylor under the Hobbs Act, which condemns anyone who "in any way or degree obstructs, delays, or affects commerce or the movement of any article or commodity in commerce, by robbery or extortion." Taylor sought to introduce evidence at his trial that the victim of the robbery dealt only in marijuana grown in-state, but the U.S. District Court for the Western District of Virginia barred admission, holding that drug dealing affects interstate commerce as a matter of law. Taylor was convicted and appealed. On appeal, he questioned whether the government had satisfied the Hobbs Act's commerce element, but he faced two obstacles. Lower federal appellate courts had generally construed the "in any way or degree" language to mean that Congress intended to exercise the full extent of its Commerce Clause powers and that the prosecution need establish no more than a de minimis impact on interstate commerce. Second, the Supreme Court's Raich decision seemed to reenforce the government's position. The Raich opinion declared that "Congress can regulate purely intrastate activity that is not itself commercial ..., if it concludes that failure to regulate that class of activity would undercut the regulation of the interstate market in that commodity." The Fourth Circuit affirmed Taylor's conviction. It concluded that "it was entirely reasonable for the jury to conclude that the robberies would have the effect of depleting the assets of an entity engaged in interstate commerce.... Because drug dealing in the aggregate necessarily affects interstate commerce, the government was simply required to prove that Taylor depleted or attempted to deplete the assets of such an operation." The Second and Seventh Circuits had expressed a somewhat different understanding. The Second Circuit had declared that "[p]roof of drug trafficking is no longer regarded as automatically affecting interstate commerce; instead, even in drug cases, the jury must find such an effect as part of its verdict." The Seventh Circuit indicated that proof of an individualized impact is not necessary for prosecution under the federal drug law, but is required for Hobbs Act prosecutions. The Supreme Court explicitly rejected the arguments of the two circuits. The resolution of the Taylor case, the Court said, "require[d] no more than ... [to] graft [its] holding in Raich onto the commerce element of the Hobbs Act." In Raich , the Court had recognized "Congress' power to regulate purely local activities that are part of an economic class of activities that have a substantial effect on interstate commerce." It also had acknowledged there that "[t]he production, possession, and distribution of controlled substances constitute a class of activities that in the aggregate substantially affect interstate commerce." In the eyes of the Court in Taylor , "the market for marijuana, including its intrastate aspects, is 'commerce over which the United States has jurisdiction.' It therefore follows as a simple matter of logic that a robber[, like Taylor,] who affects or attempts to affect even the intrastate sale of marijuana grown within the State affects or attempts to affect commerce over which the United States has jurisdiction." Justice Thomas dissented. He felt that the limits of congressional authority under the Commerce Clause required a holding that the Hobbs "Act punishes a robbery only when the Government proves that the robbery itself affected interstate commerce." H olding : "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 ques t ion to obtain that property u n der color of officia l right ." Ocasio was a Baltimore police officer, who with several other officers received kickbacks for referring accident victims to a particular auto body shop. For his efforts, Ocasio was convicted of extortion and conspiracy to commit extortion under the Hobbs Act. The Hobbs Act punishes anyone who "in any way or degree obstructs, delays, or affects commerce or the movement of any article or commodity in commerce, by ... extortion or attempts or conspires so to do." It defines extortion to include "the obtaining of property from another, with his consent ... under color of official right." Ocasio argued at trial and on appeal that the Hobbs Act does not outlaw obtaining property from a co-conspirator. His argument proceeded under alternative theories. First, he contended that a statute which punishes conspirators for obtaining the property "of another" under color of law is limited to victims who are "other" than conspirators. Second, he asserted that otherwise every victim would be liable as a conspirator: "The law must require that a victim under the Hobbs Act be a person outside the conspiracy because otherwise every victim's 'consent' could be considered an agreement to enter into a conspiracy with its victimizer, thereby creating a separately punishable conspiracy in every §1951(a) case." Ocasio claimed persuasive support from a Sixth Circuit case, U.S. v. Brock , which seemed to endorse his alternative theories. The U.S. Court of Appeals for the Fourth Circuit, however, was not convinced. It responded that Ocasio's "property of another" argument was undermined by the fact that the term "property of another" might easily mean the property of anyone other than one acting "under color of law." As for his "consent" argument, it was foreclosed by an earlier Fourth Circuit case "which underscored the proposition that mere acquiescence in an extortion scheme is not conspiratorial conduct. Rather, conduct more active than mere acquiescence is necessary before a person may depart the realm of a victim and may unquestionably be subject to conviction for aiding and abetting and conspiracy." Therefore it is "wrong to suggest that every extortion scheme will necessarily involve a conspiracy to commit extortion." The Supreme Court affirmed the Fourth Circuit's decision. The Court's conspiracy case law provided his undoing. Justice Alito wrote the opinion for the Court joined by four of his colleagues. He pointed to earlier Court decisions which held "that a person may be convicted of conspiring to commit a substantive offense that he or she cannot personally commit." They confirmed that "[i]t is sufficient to prove that the conspirators agreed that the underlying crime be committed by a member of the conspiracy who was capable of committing it." In Ocasio's case, the body shop owners could not commit extortion because they could not act "under color of official right." Nevertheless, "they could ... conspire to commit Hobbs Act extortion by agreeing to help [Ocasio] and the other officers commit the substantive offense." And as a consequence, Ocasio could be convicted of conspiring with them. Justice Alito also responded with precedent to Ocasio's argument that the Court's conspiracy theory would eliminate the distinction between extortion (coercive corruption) and bribery (consensual corruption). Justice Alito explained that the Court had already declared in Evans that Hobbs Act "color of law" extortion is the "rough equivalent of bribery." Justice Thomas dissented, as he had in Evans , because that case "erred in equating common-law extortion with taking a bribe." Justice Breyer joined in the majority opinion, but offered a concurrence acknowledging that he finds troubling, but binding, the Evans "extortion is the rough equivalent of bribery" precedent. Justice Sotomayor and Chief Justice Roberts dissented because they did not believe that "a group of conspirators can agree to obtain property 'from another' in violation of the Act even if they agree only to transfer property among themselves." Holding : Arranging a meeting or hosting an event does not qualify as an "official act" for purposes of the federal bribery statute unless it involves "the formal exercise of governmental power" with respect to some pending or anticipated "question, matter, cause, suit, proceeding or controversy."