United States v. Coss
United States Court of Appeals for the Sixth Circuit
677 F.3d 278 (2012)
Allison Coss and Scott Sippola (defendants) possessed photographs of Coss with actor John Stamos from a 2004 party and, years later, created fake email identities to contact Stamos -- first claiming Coss was pregnant with his child and had compromising photos, then demanding $680,000 to keep another set of photos from being sold. Stamos alerted federal authorities, who arrested Coss and Sippola after an associate delivered the demanded payment. The federal government (plaintiff) charged the pair with extortion under 18 U.S.C. section 875(d) for transmitting a threat to injure Stamos's reputation in interstate communications, and a jury convicted them; they appealed, arguing their conduct was lawful and that the statute was unconstitutionally vague.
Whether transmitting a threat to damage someone's reputation unless paid can constitute unlawful extortion under 18 U.S.C. section 875(d) even when the underlying conduct threatened -- such as possessing or offering to sell photographs -- is itself lawful.