The defendant police officer and a number of co-workers routed vehicles damaged in accidents to a repair shop in exchange for kickbacks. He was criminally charged with obtaining money from the body shop owners under color of official right in violation of the Hobbs Act, 18 U.S.C. 371 and conspiring to do so. The U.S. Supreme Court rejected the argument that because the Hobbs Act prohibits the obtaining of property "from another" that a Hobbs Act conspiracy required proof of agreeing to obtain property from someone outside the conspiracy. The defendant could be convicted of conspiring to violate the Act based on proof that he reached an agreement with the owners of the property in question (the shop owners) to obtain some of their property (money) under color of official right. The Court stated that its decision did not transform every bribe of a public official into a conspiracy to commit extortion. Ocasio v. United States, #14-361, 136 S. Ct. 1423, 194 L. Ed. 2d 520, 2016 U.S. Lexis 2932, 84 U.S.L.W. 4245.
     A federal appeals court upheld the criminal convictions of four police officers on charges related to the beating death of a detainee while he was in their custody. The court rejected an argument that the trial court erred by sentencing one of the defendants using the federal sentencing guidelines in effect at the time of the sentencing, rather than the more favorable provisions of a guidelines manual in effect at the time of the crime. The court rejected an argument that this violated the constitutional provision against ex post facto punishments. U.S. v. Pagan-Ferrer, #10-1518, 2013 U.S. App. Lexis 23566 (1st Cir.).