Percy Giles (defendant) was a Chicago alderman who received over $81,000 in contributions from a company, Niagra Group, that was operating an illegal dump in his ward. In exchange for the contributions, Giles repeatedly intervened on Niagra’s behalf to overturn or block officials’ attempts to force Niagra to clean up the illegal dump. Giles was eventually charged with multiple counts of racketeering, mail fraud, extortion, and related tax-fraud charges for the contributions from Niagra and other bribes. Giles was convicted. Giles appealed the convictions arising from charges of extortion under the Hobbs Act. He alleged that the prosecution must have shown that a quid pro quo existed between Giles and Niagra and that the jury should have been instructed on this requirement.