One defendant robbed local drug dealers. A second, a police officer, directed the victims of traffic accidents to a particular body shop for a kickback. A third, a state governor, accepted lavish gifts from a businessman who hoped to benefit from his largesse. All three were prosecuted under the Hobbs Act, the federal criminal statute that outlaws obstructing interstate commerce by robbery or extortion. The Hobbs Act, 18 U.S.C. § 1951, began as the Anti-Racketeering Act in 1934, which punished obstructions of commerce "by extortion, violence, coercion, or intimidation." Congress recast the statute in the Hobbs Act in 1946 and polished it in 1948 in the revision of federal criminal law. Except for an adjustment in the fine schedule, the statute has remained unchanged ever since. The Supreme Court has visited the Hobbs Act on several occasions to review the statute's related, but very distinct, crimes. One proscribes robbery and is sometimes used to prosecute street crimes. The other proscribes extortion and is often used to prosecute federal, state, and local public corruption. This is a brief overview of the Act and relevant court interpretations of its provisions. The Hobbs Act robbery proscription, described in outline form, condemns the following: (1) Whoever (2) in any way or degree (3) (a) obstructs, (b) delays, or (c) affects (4) (a) [interstate or foreign] commerce or (b) the movement of any article or commodity in commerce, (5)(a) by robbery, i.e ., (i) [knowing and willful] (ii) unlawful taking or obtaining of personal property (iii) (A) from the person or (B) in the presence of another, (iv) against his will, (v) by means of actual or threatened (A) force, (B) or violence, or (C) fear of injury, immediate or future, (vi)(A) to his person or property, (B) or property in his custody or possession, (C) or the person or property of a relative or member of his family or of anyone in his company at the time of the taking or obtaining or (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. As a general rule, the word "whoever" includes not only individuals, but also "corporations, companies, associations, firms, partnerships, societies, and joint stock companies …." Thus, corporations, labor organizations, and other legal entities may be liable for Hobbs Act violations committed by the entity's officers, employees, or members within the scope of their authority and for the benefit of the legal entity. The Hobbs Act defines "commerce" as (1) commerce into or out of a state; (2) commerce into, out of, or within the District of Columbia or any U.S. territory or possession; or (3) all other commerce over which the United States has jurisdiction." The Supreme Court has acknowledged that the Hobbs Act's jurisdictional language "manifests a purpose to use all the constitutional power Congress has to punish interference with interstate commerce by extortion, robbery, or physical violence." Nevertheless, the Constitution confines Congress's legislative authority under the Commerce and Necessary and Proper Clauses to enactments regulating (1) the channels of commerce, (2) the instrumentalities of commerce, or (3) the activities that substantially affect commerce. "[A]ctivities within this third category—those that 'substantially affect' commerce—may be regulated so long as they substantially affect interstate commerce in the aggregate, even if their individual impact on interstate commerce is minimal." 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 . Examples include the following: robbery of a business that sells products that originate in another state; robbery that results in a business having to temporarily close down; robbery that depletes the assets available to a business; robbery of a drug dealer; in some instances, robbery of an individual who regularly engages in interstate commerce; in some instances, robbery of a substantial number of individual victims or of a substantial amount from a single individual; and in some instances, robbery of an individual targeted because of his relation to commerce. Section 1951(b)(1) defines the word "robbery" as follows: [T]he unlawful taking or obtaining of personal property from the person or in the presence of another, against his will, by means of actual or threatened force, or violence, or fear of injury, immediate or future, to his person or property, or property in his custody or possession, or the person or property of a relative or member of his family or of anyone in his company at the time of the taking or obtaining. The Hobbs Act's robbery definition is built upon the common law, and consequently conviction requires proof of the use, threat, or fear of violent physical force. Although the statute has no explicit statement of mind (mens rea) requirement, a Hobbs Act robbery conviction likely requires evidence that the defendant committed robbery "knowingly." In most instances, the word "knowingly" means that the defendant consciously engaged in the conduct that the law proscribes. Congress's inclusion of the term "force or violence" within the Hobbs Act's statutory definition of robbery seems to dispense with the need for a more demanding mens rea standard. The government, however, need not prove that the defendant intended to obstruct or delay interstate commerce. The Hobbs Act explicitly condemns not just robbery, but also attempts to rob and conspiracies to rob. By operation of 18 U.S.C. § 2, it also condemns aiding and abetting a Hobbs Act robbery. All three carry the same penalties as the underlying substantive offense. "[A] person is liable under [18 U.S.C.] § 2 for aiding and abetting a crime if (and only if) he (1) takes an affirmative act in furtherance of that offense, (2) with the intent of facilitating the offense's commission." Ordinarily, the first requirement for aiding and abetting liability is that someone else commits a crime. The Hobbs Act, however, encompasses both robbery and attempted robbery. Thus, even though no robbery ever occurs, a defendant may be guilty of aiding and abetting a Hobbs Act violation if he assists someone else's attempt to commit a Hobbs Act robbery. "To be convicted of an 'attempt,' a defendant must: (1) have the specific intent to engage in the criminal conduct with which he is charged with attempting; and (2) have taken a substantial step toward the commission of the offense that strongly corroborates his criminal intent." As a general rule, conviction does not require successful commiss ion of the attempted offense. "Factual impossibility and mistake of fact are not defenses to an attempt" to commit a Hobbs Act robbery as long as the defendant intended to commit the substantive offense and took a substantial step to the satisfaction of that intent acting on facts as he believed them to be. Nor is abandonment a defense once a substantial step has been taken. "A Hobbs Act robbery conspiracy has three elements—(1) an agreement to commit Hobbs Act robbery between two or more persons, (2) the defendant's knowledge of the conspiratorial goal and (3) the defendant's voluntary participation in furthering the goal." The general federal conspiracy statute requires the government to prove that one of the conspirators committed some overt act in furtherance of the scheme. Hobbs Act robbery conspiracy has no such requirement. Nevertheless, a conspirator remains liable for crimes committed in furtherance of the scheme until the conspiratorial goal is achieved or the conspirator withdraws. One court has said that, "[f]or a defendant to show that he withdrew from the conspiracy, proof merely that he ceased conspiratorial activity is not enough." Moreover, "he must also show that he performed 'some act that affirmatively established that he disavowed his criminal association with the conspiracy,' ... either the making of a clean breast to the authorities, or communication of the abandonment in a manner reasonably calculated to reach co-conspirators." 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). Section 924(c) outlaws the use of a firearm during and in furtherance of a crime of violence, and calls for imposition of one of a series of mandatory minimums based on the type of firearm, the circumstances of its use, and the defendant's earlier criminal conduct. Until recently, every federal appellate court to consider the issue had concluded that a Hobbs Act robbery constituted a crime of violence for purposes of section 924(c). The Supreme Court's April 2018 decision in Session s v. Dimaya initially raised questions as to the continued validity of that conclusion based on the definition in Dimaya of what constitutes a crime of violence. Section 924(c) defines the term "crime of violence" as a felony either (1) with an element of physical force (the "elements clause") or (2) that involves substantial risk of physical force (the "risk clause"). The Court in Dimaya held that a comparably worded risk clause in another statute, 18 U.S.C. 16(b), was unconstitutionally vague.