Scheidler v. National Organization for Women, Inc., 547 U.S. 9 (2006)
Primary Holding
The Supreme Court held that the Hobbs Act's prohibition on "obstructing, delaying, or affecting commerce" through violence applies only to violent acts committed in furtherance of plans or purposes involving robbery or extortion, rather than to all violent actions that affect interstate commerce.
In the case of Scheidler v. National Organization for Women, the Supreme Court decided that a law meant to prevent violence in business contexts only applies when that violence is part of a plan to commit robbery or extortion. This matters because it limits how broadly the law can be used against protests or demonstrations, particularly those related to controversial issues like abortion. For consumers, this means that while they have the right to protest and express their views, those actions can't be labeled as criminal under this specific law unless they involve robbery or extortion. This case is relevant if someone is involved in protests and faces legal action claiming they are obstructing commerce.
AI-generated plain-language summary to help you understand this case
In *Scheidler v. National Organization for Women, Inc.*, 547 U.S. 9 (2006), the underlying dispute arose from the activities of pro-life petitioners, including Joseph Scheidler and various organizations, who engaged in protests against health care clinics that perform abortions. The respondents, which included these clinics and the National Organization for Women (NOW), alleged that the petitioners attempted to disrupt clinic operations through unlawful activities, including violence and intimidation. In 1986, the respondents initiated legal action seeking damages and an injunction to prevent the petitioners from continuing their protest activities, claiming that these actions constituted extortion under the Hobbs Act and related statutes. The procedural history of the case began with the respondents filing their complaint, which was initially dismissed by the District Court on the grounds that the Racketeer Influenced and Corrupt Organizations Act (RICO) required proof of an economic motive, which the court found lacking in this case. This dismissal was affirmed by the Court of Appeals for the Seventh Circuit. However, the Supreme Court later reversed this decision, clarifying that RICO does not necessitate an economic motive, and remanded the case for further proceedings. Following a trial, a jury found that the petitioners had indeed engaged in extortionate acts, leading to the current appeal. The relevant background context includes the legal framework of the Hobbs Act, which criminalizes obstruction of commerce through robbery, extortion, or threats of violence. The case raised significant questions about the interpretation of the statute, particularly regarding the scope of what constitutes violence "in furtherance of a plan or purpose" that affects interstate commerce. The Supreme Court's decision ultimately focused on whether the Hobbs Act's provisions applied solely to violent acts connected to robbery or extortion, or whether they encompassed a broader range of violent conduct impacting commerce.
Whether the phrase "in furtherance of a plan or purpose to do anything in violation of this section" in the Hobbs Act refers to violent actions connected specifically to robbery or extortion, or to all violent actions that affect interstate commerce.
The judgment is reversed.
- Court
- Supreme Court
- Decision Date
- November 30, 2005
- Jurisdiction
- federal
- Case Type
- landmark
- Damages Awarded
- N/A
- Data Quality
- high
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