United States v. Albertson

Joseph Corrado wanted to develop a manufactured-home community called Applewood Farms on land that he owned in Delaware. Corrado obtained approval from the local town council to rezone the land to allow for the development. There was substantial community opposition to the development, however. Kirk Albertson (defendant) was one of the most vocal opponents of the project. Albertson organized protests, supported political candidates who would oppose the development, and spearheaded community resistance. The conflict between Corrado and Albertson and other antidevelopment parties involved flyers, community meetings, newspaper articles, and lawsuits. After a number of months, however, Albertson told Corrado that he would stop opposing Corrado’s development of the land if Corrado would make a $20,000 sponsorship donation to Albertson’s new semi-pro football team. Corrado was immediately suspicious of Albertson’s offer and contacted a former Federal Bureau of Investigation (FBI) agent for advice. Corrado began taping his conversations with Albertson. During these conversations, Albertson admitted that he could not control the response of elected officials but that if Corrado made the donation to Albertson’s team, Albertson would stop all of his own opposition activity against the development and would attempt to influence others to do so as well. The former FBI agent contacted the FBI, and Albertson was arrested for attempted extortion under the Hobbs Act, 18 U.S.C. § 1951. At trial the jury found Albertson guilty. Albertson filed a motion for the court to grant a judgment of acquittal as a matter of law.