Since Alexander v. Sandoval (2001) 121 S.Ct. 1511, federal courts do not imply private causes of action unless a federal statute evinces an intent to create one. The Hobbs Act (18 U.S.C. § 1951) does not show any intent to create a private right of action. It is a simple criminal statute, outlawing use of robbery, extortion or threats of violence to interfere with interstate commerce. The fact that plaintiffs may be the victims of the crime so punished is not enough to show that Congress intended to give them a private right of action. That RICO specifies that a Hobbs Act violation may be a predicate RICO offense demonstrates that Congress knew how to create private rights of action and chose not to do so directly under the Hobbs Act.