Should certiorari be granted to resolve the circuit split on criminalizing baseless threats to sue as Hobbs Act extortion?

QUESTIONS PRESENTED FOR REVIEW A. — The Ninth Circuit has placed itself in conflict with several other circuits by criminalizing any baseless threat to sue as Hobbs Act extortion. This is a dangerous expansion of federal criminal liability that may have unanticipated and unfortunate consequences in other cases and in other contexts. Should certiorari should be granted to resolve this circuit split? B. Additionally, in order to sidestep the clear circuit split, the Ninth Circuit took the unprecedented and unsupported position that interpretation of a statute when applied in the criminal context can be different from an interpretation of that same statute in the civil context. This holding conflicts with several decision of this Court, including Leocal »v. Ashcroft, 543 U.S. 1 (2004). Should certiorari be granted to address the Ninth Circuit’s failure to follow binding precedent from this Court? ii