Scheidler v. National Organization for Women

Joseph Scheidler (defendant) was a member of the Pro-Life Action Network (PLAN) (defendant), a coalition of groups that opposed legal abortion. The National Organization for Woman, Incorporated (NOW) and two healthcare centers that performed abortions (plaintiffs) sued PLAN and Scheidler in the United States District Court for the Northern District of Illinois, alleging violations of the Racketeer Influenced and Corrupt Organizations Act (RICO). NOW alleged that PLAN was part of a nationwide conspiracy to shut down abortion clinics through racketeering. The allegations of racketeering included extortion in violation of the Hobbs Act. The acts complained of included using force and threats of force, violence, or fear to cause women seeking abortions and abortion-clinic workers to give up their rights to seek medical treatment and to work, respectively. After trial, a jury found PLAN had violated civil provisions of RICO and committed 21 violations of the Hobbs Act by engaging in a pattern of racketeering activity. The jury awarded monetary damages to NOW members. The district court issued a permanent injunction against PLAN regarding its misconduct towards abortion clinics. The court of appeals affirmed the jury verdict. The court of appeals found that intangible property rights may be considered property under the Hobbs Act and that extortion does not require the seeking of money or other tangible property. PLAN appealed to the United States Supreme Court.