United States v. Sturm

John Sturm (defendant) received a loan from the Worcester County Institution for Savings (WCIS) to purchase an Aero Commander aircraft. The loan was secured by the aircraft itself, as well as the plane’s logbooks. Logbooks were required for all commercial aircrafts. After several missed payments, WCIS learned that Sturm had financial problems and repossessed the plane without the logbooks. However, WCIS learned that it could not obtain a fair auction price for the plane without the logbooks. WCIS asked Sturm to return the logbooks on various occasions. Sturm told WCIS representatives that he did not know where the logbooks were but would return the books for a fee of $20,000. Thereafter, WCIS contacted the Federal Bureau of Investigation (FBI). WCIS then informed Sturm that the fee had been approved. Shortly thereafter, FBI agents posing as WCIS officers met with Sturm. The FBI agents arrested Sturm after he showed the agents the logbooks. Sturm was charged with and convicted of attempted extortion in violation of the Hobbs Act, 18 U.S.C. §1951, which punishes anyone who affects interstate commerce by robbery or extortion. Extortion is defined as the obtaining of property from another with consent by the wrongful use of threats, force, violence, or fear. At trial, the judge instructed the jury that Sturm had a claim-of-right defense and that the government was not required to prove that Sturm knew his acts were illegal. The jury rendered a verdict finding Sturm guilty of attempted extortion. Sturm appealed.