In the case of Carbo v. United States (1960), Frank "Blinky" Palermo and Frankie Carbo, both boxing promoters, were convicted for violating the federal anti-racketeering law known as the Hobbs Act. The defendants had been using threats of violence to extort money from a professional boxer and his manager in exchange for allowing them to participate in interstate boxing matches. On appeal, they argued that their actions did not constitute extortion under the Hobbs Act because they didn't physically obstruct or interfere with interstate commerce; rather, they merely influenced it through coercive tactics. The Supreme Court disagreed with this interpretation and upheld their convictions. It ruled that any form of coercion used to obtain property or advantages can be considered obstruction if it affects commerce indirectly by influencing its natural course. This broad interpretation expanded federal jurisdiction over crimes traditionally prosecuted at state level such as robbery and extortion when these activities affect interstate commerce even indirectly.

In the dissenting opinion for Carbo v. United States, Justice Hugo Black argued that the majority's decision to uphold a conviction based on evidence obtained through wiretapping was in violation of both Fourth and Fifth Amendment rights. He contended that allowing such evidence not only violated an individual's right against unreasonable searches and seizures but also their right against self-incrimination as it forced them to provide evidence against themselves without due process of law. Furthermore, he criticized the court for failing to address these constitutional issues directly in its ruling, instead focusing on technicalities related to jurisdictional matters. In his view, this approach undermined fundamental principles of justice and fairness enshrined within the Constitution.