United States v. Nardello

Background

A group of private individuals was indicted under a federal law called the Travel Act for running a shakedown operation. The indictment says they lured people into a compromising homosexual situation and then threatened to expose them unless paid, and that they traveled across state lines to further the scheme (twice from New Jersey to Philadelphia and once from Chicago to Philadelphia). The federal trial court dismissed the indictments because Pennsylvania law labels the conduct as "blackmail" while Pennsylvania’s separate extortion statute applies only to public officials.

Reasoning

The Court considered whether the Travel Act’s use of the word "extortion" should be read narrowly to mean only public-official corruption or broadly to cover extortionate acts regardless of a State’s label. Looking at Congress’s purpose—to help local law enforcement combat organized crime that crosses state lines—the Court concluded Congress intended a generic meaning: obtaining money by threats or fear is extortion for the Travel Act even when a State calls it blackmail or uses other labels. The Court noted many States use different names for the same conduct and that reading the statute narrowly would frustrate Congress’s goal.

Real world impact

The Court reversed the dismissal and sent the case back to the lower court for further proceedings. The decision means federal prosecutors can reach interstate shakedown and extortion schemes even when state law uses different labels. Justice White did not take part in the decision.