United States v. Jackson
United States Court of Appeals for the Second Circuit
180 F.3d 55 (1999)
Autumn Jackson (defendant), whose mother claimed she was actor Bill Cosby's daughter, received decades of financial support from Cosby, including a college trust, but the trust stopped paying after she dropped out of school. Struggling financially, Jackson eventually threatened Cosby's attorneys that she would sell her story of being his homeless daughter to the media unless paid, and when initial demands failed she and Jose Medina secured a tabloid's written $25,000 offer and tried to leverage it into a $40 million settlement demand sent through Cosby's attorneys and CBS officials. Cosby contacted the FBI, leading to a sting arrest of Jackson, Medina, and an associate, Boris Sabas; Jackson and Medina were convicted under a federal statute criminalizing threats to reputation made to extort money, and they appealed the jury instructions for failing to require that the threat be wrongful.
Whether a conviction for threatening another's reputation with intent to extort money requires the jury to find that the threat itself was wrongful, rather than merely that a threat to reputation was made with extortionate intent.