In the United States v. Culbert case of 1977, the U.S Supreme Court ruled that a defendant does not need to have an organized criminal connection for their conviction under the Hobbs Act. The court's decision came after Robert Wayne Culbert was convicted for extorting money from two individuals by threatening them with physical harm unless they paid him $500 each week. He appealed his conviction arguing that he should not be prosecuted under the Hobbs Act because it only applies to those involved in racketeering or some form of organized crime, which he wasn't part of. However, Justice Brennan writing for a unanimous court rejected this argument stating that there is no language in the statute indicating such requirement and thus affirmed his conviction.

In the dissenting opinion for United States v. Culbert, 1977, Justice Marshall argued that the majority's interpretation of the Hobbs Act was too narrow and failed to consider Congress' intent when enacting it. He contended that by limiting its application only to those who commit robbery or extortion in a manner "affecting commerce," rather than including all individuals who obstruct, delay or affect commerce through such acts regardless of their purpose, undermines Congress’ broad aim to protect interstate commerce from any form of interference. The justice believed this approach would exclude many potential offenders whose actions could significantly impact interstate trade but do not fit into traditional definitions of robbery or extortion - an outcome he felt was inconsistent with legislative intent.