United States V. Enmons - Details of The Case

Details of The Case

The indictment against the alleged conspirators charged them with being in violation of the Hobbs Act, which states that anyone attempting to affect or obstruct commerce through violence or the threat of violence against any person or property "shall be fined not more than $10,000 or imprisoned not more than twenty years, or both." The indictment argued that the union members obstructed commerce with their actions against the Utilities Company, and attempted to "obtain the property of in the form of wages and other things of value" by using the wrongful use of force and the fear of economic loss.

The court acknowledged that using threats and force to obtain property is wrongful. However, the court reasoned that it is considered "wrongful" only when the perpetrator has no "legitimate claim" to it. Since federal law empowers unions with the right to strike, the use of violence to secure higher pay and benefits was not extortion. The case was dismissed. The court's ruling set a legal precedent where violent acts against an employer by workers on strike, including destruction of property, assault, and homicide, are not punishable offenses under federal law. They can, however, be punishable under state or federal civil and criminal laws. These laws can include assault and battery, murder, and theft, among others.

In understanding Enmons, it is important to keep in mind that what the Hobbs Act outlaws is extortion, not just any bad act. Federal law, in particular the National Labor Relations Act, says that collective bargaining and strikes in support of collective bargaining goals are legal and protected. Therefore, since collective bargaining is purpose that is not extortion, one of the key elements of a Hobbs Act violation is not met.

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