N.J. Stat. » Title 2C — THE NEW JERSEY CODE OF CRIMINAL JUSTICE
New Jersey Statutes

N.J. Stat. § 2C:20-5 (2026)

Theft by extortion

✓ current as of May 2026
Find cases: SyfertCases citing this section JustiaN.J. Stat. CornellLII Search CasesGoogle Scholar

A person is guilty of theft by extortion if he purposely and unlawfully obtains property of another by extortion. A person extorts if he purposely threatens to:

a. Inflict bodily injury on or physically confine or restrain anyone or commit any other criminal offense;

b. Accuse anyone of an offense or cause charges of an offense to be instituted against any person;

c. Expose or publicize any secret or any asserted fact, whether true or false, tending to subject any person to hatred, contempt or ridicule, or to impair his credit or business repute;

d. Take or withhold action as an official, or cause an official to take or withhold action;

e. Bring about or continue a strike, boycott or other collective action, if the property is not demanded or received for the benefit of the group in whose interest the actor purports to act;

f. Testify or provide information or withhold testimony or information with respect to another's legal claim or defense; or

g. Inflict any other harm which would not substantially benefit the actor but which is calculated to materially harm another person.

It is an affirmative defense to prosecution based on paragraphs b, c, d or f that the property obtained was honestly claimed as restitution or indemnification for harm done in the circumstances or as lawful compensation for property or services.

Notes of Decisions
Cited in 28 cases (8 in the last 5 years), 1985–2026 · leading case: State v. Aloi, 204 A.3d 297 (N.J. Super. Ct. App. Div. 2019).
Sort: Relevance Newest Treatment
State v. Aloi, 204 A.3d 297 (N.J. Super. Ct. App. Div. 2019). · cites it 8× “2C:20-5(c) ; see also Model Jury Charge (Criminal) , "Theft By Extortion ( N.J.S.A. 2C:20-5 )" (rev. June 5, 2006). To establish criminal attempt, the State was required to present some evidence defendant "[p]urposely" did "anything which, under the circumstances as a reasonable…”
Kaul v. Christie, 372 F. Supp. 3d 206 (D.N.J. 2019). · cites it 2× “Testify or provide information or withhold testimony or information with respect to another's legal claim or defense; or g.”
State v. Taccetta, 693 A.2d 1229 (N.J. Super. Ct. App. Div. 1997). · cites it 2× “SA 2C:20-5; 2C:2-6); and Accetturo and Ricciardi with second-degree theft by extortion (count seven, N.J.S.A. 2C:20-5; 2C:2-6). All defendants except Sodano were tried together before a jury.”
Apple Corps Ltd. v. Int'l Collectors Soc'y, 15 F. Supp. 2d 456 (D.N.J. 1998). · cites it 2× “§ 2C:20-5 (West 1995). The essence of extortion is duress.”
State v. Roth, 673 A.2d 285 (N.J. Super. Ct. App. Div. 1996). · cites it 2× “2C:20-5g was intended to be a "catch-all" provision, criminalizing "other threats" not specifically covered by preceding subsections: *160 Examples of situations which might occur and not be covered in other Subsections are: (a) the foreman in a manufacturing plant requires the…”
Cnty. of Hudson v. Janiszewski, 520 F. Supp. 2d 631 (D.N.J. 2007). “2C:27-10, and theft by extortion, N.J.S.A. 2C:20-5. Plaintiffs also allege as a predicate offense the crime of offer of unlawful benefit to public servant for official behavior, in violation of N.”
Yuhasz v. Poritz, 166 F. App'x 642 (3rd Cir. 2006). · cites it 2× “See N.J. Stat. Ann. § 2C:20-5. However, Yuhasz does not allege that any Defendant threatened her with conduct prohibited under the statute, an essential element of the crime.”
State of New Jersey v. George E. Norcross, III (N.J. Super. Ct. App. Div. 2026). · cites it 36× “§ 1951 (Hobbs Act); (2) theft by extortion, N.J.S.A. 2C:20-5; (3) financial facilitation of criminal activity, N.”
Prime Healthcare Servs., Inc. v. Servs. Employees Int'l Union, 147 F. Supp. 3d 1094 (S.D. Cal. 2015). “or a promise____”); N.J. Stat. Ann. § 2C:20-5 ("A person extorts if he purposely threatens to (a) Inflict bodily injury on or physically confine or restrain anyone or commit any'other crimi- .”
State of New Jersey Vs. Robert Aloi (18-02-0295, Middlesex Cnty. & Statewide) (N.J. Super. Ct. App. Div. 2019). · cites it 8× “A-5669-17T1 8 "Theft By Extortion (N.J.S.A. 2C:20-5)" (rev. June 5, 2006). To establish criminal attempt, the State was required to present some evidence defendant "[p]urposely" did "anything which, under the circumstances as a reasonable person would believe them to be, is an…”
State of New Jersey v. Frank Nucera (N.J. Super. Ct. App. Div. 2024). · cites it 4× “Also, although N.J.S.A. 2C:20-5 defines seven forms of the crime of theft by extortion, see N.”
United States v. Accetturo, 623 F. Supp. 746 (D.N.J. 1985). “8 United States Code Section 1955 ; mail fraud in violation of 18 United States Code Sections 1341 and 2; wire fraud in violation of 18 United States Code Sections 1343 and 2; Hobbs Act extortion in violation of 18 United States Code Sections 1951 and 2; extortionate credit…”
Show all 28 citing cases →
— N.J. Stat. § 2C:20-5(a) — 7 cases
State v. Aloi, 204 A.3d 297 (N.J. Super. Ct. App. Div. 2019). “2C:20-5(c) ; see also Model Jury Charge (Criminal) , "Theft By Extortion ( N.J.S.A. 2C:20-5 )" (rev. June 5, 2006). To establish criminal attempt, the State was required to present some evidence defendant "[p]urposely" did "anything which, under the circumstances as a reasonable…”
State of New Jersey Vs. Brooke L. Hoffman (14-12-1340, Middlesex Cnty. & Statewide) (N.J. Super. Ct. App. Div. 2019).
State of New Jersey v. Martin Taccetta (91-04-0063, Ocean Cnty. & Statewide) (N.J. Super. Ct. App. Div. 2022).
State of New Jersey v. George E. Norcross, III (N.J. Super. Ct. App. Div. 2026). “§ 1951 (Hobbs Act); (2) theft by extortion, N.J.S.A. 2C:20-5; (3) financial facilitation of criminal activity, N.”
State of New Jersey Vs. Antoine J. Martin (14-12-1340, Middlesex Cnty. & Statwide) (N.J. Super. Ct. App. Div. 2019).
— N.J. Stat. § 2C:20-5(b) — 1 case
Care One Mgmt. LLC v. United Healthcare Workers East (3rd Cir. 2021).
— N.J. Stat. § 2C:20-5(c) — 2 cases
State v. Aloi, 204 A.3d 297 (N.J. Super. Ct. App. Div. 2019). “2C:20-5(c) ; see also Model Jury Charge (Criminal) , "Theft By Extortion ( N.J.S.A. 2C:20-5 )" (rev. June 5, 2006). To establish criminal attempt, the State was required to present some evidence defendant "[p]urposely" did "anything which, under the circumstances as a reasonable…”
State of New Jersey Vs. Robert Aloi (18-02-0295, Middlesex Cnty. & Statewide) (N.J. Super. Ct. App. Div. 2019). “A-5669-17T1 8 "Theft By Extortion (N.J.S.A. 2C:20-5)" (rev. June 5, 2006). To establish criminal attempt, the State was required to present some evidence defendant "[p]urposely" did "anything which, under the circumstances as a reasonable person would believe them to be, is an…”
— N.J. Stat. § 2C:20-5(d) — 3 cases
State of New Jersey v. Frank Nucera (N.J. Super. Ct. App. Div. 2024). “Also, although N.J.S.A. 2C:20-5 defines seven forms of the crime of theft by extortion, see N.”
State of New Jersey v. George E. Norcross, III (N.J. Super. Ct. App. Div. 2026). “§ 1951 (Hobbs Act); (2) theft by extortion, N.J.S.A. 2C:20-5; (3) financial facilitation of criminal activity, N.”
Care One Mgmt. LLC v. United Healthcare Workers East (3rd Cir. 2021).
— N.J. Stat. § 2C:20-5(e) — 1 case
Care One Mgmt. LLC v. United Healthcare Workers East (3rd Cir. 2021).
— N.J. Stat. § 2C:20-5(g) — 2 cases
State of New Jersey v. George E. Norcross, III (N.J. Super. Ct. App. Div. 2026). “§ 1951 (Hobbs Act); (2) theft by extortion, N.J.S.A. 2C:20-5; (3) financial facilitation of criminal activity, N.”
State of New Jersey v. Martin Taccetta (91-04-0063, Ocean Cnty. & Statewide) (N.J. Super. Ct. App. Div. 2022).
Annotations are extracted automatically from the opinions in the Syfert caselaw corpus and ranked by authority, recency, and treatment. Dots show Syfertize treatment of the citing case itself.