Woodward v. State

Woodward's (defendant) wife loaned $8,000 to Lyle, who tried to repay it by leaving the money with Cooper at a bar for Woodward's wife — but Cooper kept the money instead of passing it along. When Woodward learned this, he demanded payment from Cooper, threatening to break his legs if he refused; Cooper reported the threats, and Woodward was charged with extortion. At trial, Woodward sought a jury instruction allowing acquittal if the jury found Cooper actually owed him the money; the trial judge refused, instead instructing the jury that a claim of right was not a defense to this type of extortion charge, and Woodward was convicted.

Whether a person who obtains property by threatening physical injury upon another may defend against a charge of extortion by establishing a claim of right to the property.