## Facts

- A national women’s rights organization and two abortion clinics brought a nationwide class action against anti-abortion organizations and activists.
- Plaintiffs alleged a coordinated campaign to shut down abortion clinics through blockades, threats, and physical obstruction.
- Plaintiffs asserted civil liability under RICO, alleging predicate acts of extortion under the Hobbs Act, along with related state-law extortion and Travel Act predicates.
- The “property” alleged to have been taken included women’s ability to obtain clinic services, doctors’ ability to perform their work, and clinics’ ability to operate their businesses.
- A jury found a RICO violation and the district court entered damages and a permanent nationwide injunction.
- The court of appeals affirmed, concluding the defendants had “obtained” property as required for Hobbs Act extortion and that private RICO plaintiffs could obtain injunctive relief.

## Issues

1. Whether interference with clinic operations through blockades, threats, and obstruction constituted “extortion” under the Hobbs Act because defendants “obtained” plaintiffs’ property, permitting those acts to serve as RICO predicates.
2. If a civil RICO violation was established, whether private plaintiffs may obtain injunctive relief under RICO.

## Decision

- The Supreme Court reversed, holding the defendants did not commit Hobbs Act extortion because they did not “obtain” property from the plaintiffs.
- The Court concluded that even if plaintiffs’ asserted interests qualified as “property,” defendants merely interfered with or deprived plaintiffs of exercising property rights, without acquiring transferable control or something of value.
- Because the extortion predicates failed, the predicate acts supporting the jury’s RICO verdict were insufficient; the civil RICO judgment could not stand.
- The Court vacated the injunction and did not reach whether private plaintiffs may obtain injunctive relief under RICO.
- The judgment was 8–1.

## Legal Principles

- Hobbs Act extortion requires “obtaining” property from another; this entails both deprivation to the victim and acquisition by the defendant.
- Coercive interference with another’s use of property, without the defendant’s acquisition of something of value that can be exercised, transferred, or sold, is not Hobbs Act extortion.
- Civil RICO liability requires valid predicate acts; when the predicates fail as a matter of law, the RICO judgment and any relief premised on it must be set aside.
- When reversal on the merits eliminates the RICO violation, a court need not decide disputed questions about the availability of private injunctive relief under RICO.

## Conclusion

The Court held that protest activity disrupting abortion-clinic operations did not qualify as Hobbs Act extortion because the defendants did not “obtain” the plaintiffs’ property, and it reversed the civil RICO judgment and vacated the nationwide injunction without deciding whether private RICO plaintiffs may seek injunctive relief.


Scheidler v. Nat'l Org. for Women, Inc., 537 U.S. 393 (2003)