## Facts

- Joseph Steining suspected his employee, Joseph N. Da Rosa, of stealing goods worth under $50; Da Rosa was arrested for petit larceny, admitted the theft, and offered reimbursement.
- Steining hired Beggs, an attorney, in connection with the theft matter.
- Beggs learned Da Rosa had about $2,500 on deposit in two banks.
- Evidence showed Beggs told Da Rosa the matter was “very serious” and that Da Rosa would be sent to prison for seven to ten years unless he immediately paid $2,000 to “settle the claims” with Steining.
- Acting out of fear of imprisonment, Da Rosa accompanied Beggs to obtain his bank book, withdrew $2,000 from the banks, and delivered it to Beggs.
- Beggs later gave approximately $900 to Steining and kept the remainder.
- Beggs was charged and convicted of extortion based on obtaining money by threats to accuse and prosecute Da Rosa for a crime and to cause imprisonment unless payment was made.

## Issues

1. Whether demanding money by threatening criminal accusation or prosecution can be treated as lawful “debt collection” when the amount demanded corresponds to a just claim.
2. Whether threats to accuse or prosecute a person for a crime to obtain money constitute extortion even if the threatened accusation is true and the victim committed the crime.
3. Whether the trial court committed reversible error by refusing defense-requested “debt collection” jury instructions and by making challenged evidentiary rulings, including treating Da Rosa as a non-accomplice whose testimony did not require corroboration.

## Decision

- The California Supreme Court affirmed the conviction and the order denying a new trial.
- The court held that obtaining money with consent induced by fear created through threats to accuse or prosecute for a crime falls within the Penal Code’s extortion provisions.
- The court rejected the defense theory that the payment was insulated from extortion liability because it was in satisfaction of a just debt.
- The court found no reversible instructional or evidentiary error.
- The court held Da Rosa was not an accomplice to extortion because he paid under coercion and fear, so his testimony did not require accomplice corroboration.

## Legal Principles

- Extortion is established when a defendant obtains property with the victim’s consent induced by a wrongful use of fear, including fear produced by threats to accuse the victim of a crime or to pursue prosecution.
- The legitimacy of the underlying claim (including satisfaction of a “just debt” or restitution for an actual wrongdoing) does not excuse using threats of criminal accusation or imprisonment to obtain payment.
- A victim who yields money under fear generated by extortionate threats is not an accomplice to the extortion and is not subject to accomplice-testimony corroboration requirements.

## Conclusion

The court upheld an extortion conviction where an attorney used threats of criminal prosecution and imprisonment to compel immediate payment, holding that threats as a collection tactic are unlawful even when the demanded sum relates to an otherwise valid claim, and that the coerced payor is a victim rather than an accomplice.


People v. Beggs, 178 Cal. 79, 172 P. 152 (Cal. 1918)