Federal Extortion Charges May Not Always Be What They Seem (18 U.S. Code Section 1951)
Alfred Nash Villalobos was an attorney serving the needs of his client Orit Anjel. Angel was fired from her job as a religious worker for the Los Angeles Chabad Israel Center. As a worker at the Center, Anjel was allegedly participating in a scam wherein she would give her paychecks back to the director, Rabbi Amitai Yemeni, in exchange for her visa to stay in the United States.1
When she was terminated, Anjel needed legal help from Villalobos to get the money she paid to Rabbi Yemeni back. However, the government was already investigating the Center and Yemeni for the alleged visa scam. They wanted to interview Anjel as part of the investigation.2
Upon realizing this, Villalobos went to Rabbi Yemeni and his attorney and demanded payment on behalf of his client. Villalobos says he was just trying to help Anjel get her money back for her work at the Center. However, the government says he had a different agenda.3
Prosecutors claim that Villalobos told Yemeni that his client would “do whatever it is we need her to do” in exchange for her money. In other words, she would help with the investigation of Yemeni and the Center by lying to a grand jury on his behalf. Villalobos also allegedly told Yemeni that Anjel would impede U.S. Attorney Keri Axel’s investigation as long as she got her payment for her work.4
Yemeni’s attorney notified the government of Villalobos’s alleged actions and agreed to record their next several conversations. Villalobos was recorded saying several things relating to exchanging money for favorable testimony. He was charged with one count of attempted extortion and was later found guilty.5
What the Villalobos Ruling Means to You (18 U.S. Code Section 1951)
Villalobos was convicted of extortion under 18 U.S. Code Section 1951. Under this law, anyone who obstructs, delays or affects commerce by extortion or attempts to do so can be found guilty of a felony.6 Villalobos was allegedly affecting commerce by demanding money from Yemeni and his attorney.
Extortion is defined as “the obtaining of property from another, with his consent, induced by wrongful use of actual or threatened force.”7 Villalobos was also committing an act of extortion to obtain money by promising to have Anjel give favorable testify in the investigation of the Los Angeles Chabad Israel Center.
Although Villalobos appealed his conviction to the United States Court of Appeals for the Ninth Circuit, it was not overturned. He argued that his actions were not “wrongful” under 18 U.S. Code Section 1951 because his client was lawfully owed the money that he was demanding. He also did not use any threat of violence.
Even though Villalobos did not issue a violent threat for Anjel’s money, the threat of testifying was made with “the intent to induce fear or take advantage of fear.”8 This shows that you do not have to use violence to be charged with extortion under 18 U.S.C. Section 1951.
Consequences of a Conviction of Federal Extortion Charges
You face harsh punishment if you are convicted of extortion under federal law. Consequences of an extortion conviction include jail times and fines.
Under 18 U.S. Code Section 1951, extortion is charged as a felony. If you are convicted of extortion, your punishment could include up to 20 years in prison and fines of up to $10,000.
Contact Your Criminal Defense Attorneys at Wallin & Klarich Today
If you are facing allegations of extortion or interference with commerce by threats or violence, the consequences can be very severe. 18 U.S.C. Section 1951 says that a violation of this law can land you in prison for up to 20 years. You will also face hefty fines if found guilty. This is why it is crucial to contact an experienced federal defense attorney. The attorneys at Wallin & Klarich have been successfully defending our clients accused of federal crimes for over 40 years.
With offices located in Orange County, San Bernardino, Los Angeles, Torrance, Riverside, West Covina, Victorville, Ventura, San Diego and Sherman Oaks, our knowledgeable attorneys are available to help you no matter where you work or live.
Call us today at (877) 4-NO-JAIL or (877) 466-5245 for a free phone consultation. We will get through this together.
1. [http://cdn.ca9.uscourts.gov/datastore/opinions/2014/04/11/12-50300.pdf]↩
2. [Id.]↩
3. [Id.]↩
4. [Id.]↩
5. [Id.]↩
6. [http://www.law.cornell.edu/uscode/text/18/1951]↩
7. [http://cdn.ca9.uscourts.gov/datastore/opinions/2014/04/11/12-50300.pdf]↩
8. [Id.]↩
