Ransom Demand Prosecutions
What is a Ransom Demand?
A ransom demand usually refers to a criminal request for money or property in exchange for the release of a kidnapped person or property. It is often part of kidnapping, extortion, or wire fraud offenses.
Key Federal Statutes Used:
18 U.S.C. § 1201 — Kidnapping (including kidnapping for ransom)
18 U.S.C. § 1951 — Hobbs Act (extortion affecting interstate commerce)
18 U.S.C. § 875(d) — Interstate communications with intent to extort
RICO Act — Used in cases involving organized criminal enterprises demanding ransom
Elements Prosecutors Must Prove
The defendant unlawfully seized, confined, or carried away a person or property (in kidnapping cases).
The defendant made a demand for ransom or property.
The demand was communicated to the victim or third parties.
The defendant intended to induce payment or compliance by the victim.
Detailed Case Law Examples
1. United States v. Khalil (2013)
Court: U.S. District Court for the Eastern District of New York
Facts:
Khalil was convicted for kidnapping a business owner and demanding a ransom.
Outcome:
Convicted under 18 U.S.C. § 1201 and sentenced to 30 years.
Significance:
Showed strict penalties for ransom kidnapping under federal law.
2. United States v. Jamieson (1998)
Court: 7th Circuit Court of Appeals
Facts:
Jamieson used interstate phone calls to demand ransom for a kidnapped victim.
Outcome:
Convicted under 18 U.S.C. § 875(d) for using communication to extort.
Significance:
Highlighted use of wire communication statutes in ransom cases.
3. United States v. Robledo (2011)
Court: 2nd Circuit Court of Appeals
Facts:
Robledo kidnapped a person and demanded ransom; prosecution under the Hobbs Act.
Outcome:
Conviction affirmed under 18 U.S.C. § 1951 for extortion.
Significance:
Demonstrated the Hobbs Act’s application in ransom-related extortion.
4. United States v. Eisenberg (2004)
Court: U.S. District Court for the District of Columbia
Facts:
Eisenberg and co-conspirators kidnapped a wealthy individual and demanded ransom.
Outcome:
Convicted under kidnapping and conspiracy statutes.
Significance:
Reinforced prosecution of ransom conspiracies using multiple statutes.
5. United States v. Bryant (2017)
Court: U.S. District Court for the Northern District of California
Facts:
Bryant ran a ransomware scheme demanding payment in cryptocurrency to unlock victims’ data.
Outcome:
Convicted of extortion and wire fraud.
Significance:
Shows modern ransom demand prosecutions involving cyber extortion.
6. United States v. Alvarado (2009)
Court: 11th Circuit Court of Appeals
Facts:
Alvarado kidnapped a businessman and demanded ransom.
Outcome:
Court upheld conviction under kidnapping-for-ransom statute.
Significance:
Confirmed the broad reach of federal kidnapping statutes in ransom cases.
Summary of Legal Principles
Ransom demands can involve kidnapping or extortion laws.
Federal statutes cover physical kidnapping and also ransom demands via communications.
Penalties are severe — often decades in prison.
Use of communication tools like phones or internet often triggers additional charges.
Prosecutors rely on evidence like ransom notes, recorded calls, witness testimony, and intercepted communications.
Modern ransom demands include cyber extortion (ransomware).
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