101) As Judge Noonan writes, this effectively eliminated any line between bribery and extortion under color of official right, because "no briber pays unless he thinks it is necessary to pay.
20 ("Codifications of the common law that did not include an express corrupt state of mind element, such as the Field Code, may have obscured the common law definition of color of right extortion.
2010) (holding that victims of extortion can still be guilty of bribery).
2009) (noting that, although McCormick spoke only to campaign contributions, almost every circuit requires a quid pro quo for extortion under color of official right).
concurring) (opining that the word "induced" applies to official right extortion, yet is satisfied by the existence of a quid pro quo); Lindgren, supra note, at 1716 ("Thus, while I agree with Justice Thomas that the word 'induced' probably applies to official extortion, I agree with Justice Stevens and the majority that the word 'induced' adds nothing to the other elements required for extortion.
2010) (refusing to extend official right extortion under the Hobbs Act to candidate for public office who never won election), with United States v.
Sentencing Guidelines aim to coordinate the incarceration periods for bribery, official right extortion, and honest services fraud.
On March 2, 1942 the Supreme Court infamously upheld the Second Circuit's reversals of extortion convictions for the Local 807 branch of the International Brotherhood of Teamsters in United States v.
Local 807 set the stage for the enactment of the Hobbs Act, the federal government's comprehensive extortion statute.