United States v. Jackson

William “Bill” Cosby, Jr., a well-known actor, had an affair with Shawn Thompson. Afterward, Thompson gave birth to Autumn Jackson (defendant) and informed Cosby that Cosby was Jackson’s father. Cosby disputed the paternity claim, but still provided financial support to Jackson for over 20 years. Cosby also established a trust to cover Jackson’s college expenses. In 1995, the attorneys managing Jackson’s college trust learned that Jackson had dropped out of school. The attorneys stopped payments to Jackson. In 1996, Jackson was struggling financially and contacted Cosby by leaving a message under the name Autumn Cosby. In the message, Jackson informed Cosby that she was homeless and needed $2,100. After admonishing Jackson for using his last name, Cosby gave Jackson the funds. When Cosby’s attorneys denied Jackson’s requests for additional funds again in January 1997, Jackson threatened Cosby’s attorneys that she would go to the media with her story of being Cosby’s homeless daughter. When this threat failed, Jackson and Jose Medina (defendant), owner of the production company where Jackson worked, secured a written offer from a tabloid for $25,000. Jackson attempted to send the written offer, along with demands for a settlement of $40 million, to Cosby through his attorneys and CBS officials. Cosby contacted the Federal Bureau of Investigation (FBI), which resulted in the arrest of Jackson, Medina, and a Boris Sabas (defendant) as a part of the FBI’s sting operation. Sabas was a colleague of Medina and Jackson who had driven the two to the airport when they flew to New York. Jackson and Medina were convicted of threatening to harm another’s reputation with the intent to extort money under 18 U.S.C. § 875(d). Jackson and Medina appealed on the ground that the jury instruction erroneously failed to require that a threat under § 875(d) be wrongful.