In the case of Ocasio v. United States, 2015, Samuel Ocasio, a former Baltimore police officer was convicted under the Hobbs Act for obtaining payments from owners of an auto repair shop in exchange for referring stolen vehicles to their business. The Supreme Court upheld his conviction by rejecting his argument that he could not be charged with conspiracy as both bribe giver and receiver were part of the same plot. The court ruled that a public official can be prosecuted for conspiring to violate federal anti-bribery law even if all participants in the scheme are public officials who accepted bribes. This decision reaffirmed that anyone involved in carrying out such corrupt activities is liable under federal law regardless of their role within it.

In the dissenting opinion for OCASIO v. UNITED STATES, Justice Breyer argued that the majority's interpretation of the Hobbs Act was incorrect and overly broad. He contended that a public official who accepts bribes does not necessarily conspire to obtain property from another under the Hobbs Act because they are not obtaining property from someone outside of their conspiracy; rather, they are receiving a bribe from a co-conspirator. According to Justice Breyer, this interpretation could potentially criminalize many ordinary activities and blur the line between federal and state law enforcement responsibilities. Furthermore, he disagreed with applying traditional principles of conspiracy law in this case as it would lead to an unnatural reading of statutory language.