United States v. Green

Background

An Illinois union local and a union official named Green were indicted after a jury found them guilty of trying to obtain wages for so‑called "swampers" — extra, unwanted laborers — by means of force or threats. The trial court denied requests for acquittal or a new trial but then arrested the judgments, saying the charged conduct did not fall within the federal extortion law and that the court lacked jurisdiction. The Government appealed directly to this Court under the statute allowing certain direct appeals.

Reasoning

The core question was whether the Hobbs Act’s definition of extortion covers efforts to obtain wages from employers during labor disputes. The Court examined the statute and its history and noted that Congress removed an earlier exclusion that had protected some employer‑employee arrangements. The majority concluded the statute reaches the alleged conduct and that extortion under the Hobbs Act does not depend on whether the taker personally benefited. The Court said it was deciding only from the words of the indictment, not from trial evidence, and therefore reversed the district court’s arrest of judgment and sent the case back for further proceedings.

Real world impact

The ruling means similar labor‑related uses of force or threats can be prosecuted under the federal extortion law, affecting unions, contractors, and federal enforcement choices. Because the Court acted on the indictment’s allegations rather than the trial record, this is not a final resolution of guilt; the case returns to the lower court for further steps.

Dissents or concurrances

Justice Douglas (joined by two others) dissented, arguing the Government lacked a proper direct appeal because the district court also relied on evidence‑based reasons, not solely on statutory construction, and would have dismissed the appeal.