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Boyle v. United States

Supreme Court of the United States
556 U.S. 938, 129 S. Ct. 2237 (2009)
ELI5:

Rule of Law:

An association-in-fact enterprise under the Racketeer Influenced and Corrupt Organizations Act (RICO) must have a structure, but that structure need only consist of a common purpose, relationships among its members, and longevity sufficient to pursue its purpose; it does not require a formal hierarchy or a structure separate from the pattern of racketeering activity.


Facts:

  • During the 1990s, a core group of individuals, along with others recruited periodically, participated in a series of bank thefts across several states.
  • The group, which was loosely and informally organized, typically targeted night-deposit boxes.
  • The group did not have an apparent leader, hierarchy, or long-term master plan.
  • Before each theft, participants would meet to plan the crime, gather tools, and assign roles such as lookout and driver.
  • The participants generally split the proceeds from the successful thefts.
  • By 1994, petitioner Boyle had joined the group.
  • Over the next five years, Boyle participated in numerous attempted thefts and burglaries with the group.

Procedural Posture:

  • Boyle was indicted in a U.S. District Court for, among other things, violating RICO.
  • At trial, the District Court rejected Boyle's proposed jury instruction requiring proof of an 'ascertainable structural hierarchy distinct from the charged predicate acts.'
  • The jury convicted Boyle on the RICO counts.
  • Boyle appealed his conviction to the U.S. Court of Appeals for the Second Circuit.
  • The Court of Appeals affirmed the conviction in a summary order, deeming Boyle's arguments regarding the jury instructions to be 'without merit.'
  • The U.S. Supreme Court granted certiorari to resolve a conflict among the Courts of Appeals concerning the definition of a RICO enterprise.

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Issue:

Does an 'association-in-fact enterprise' under the Racketeer Influenced and Corrupt Organizations Act (RICO) require an ascertainable structure beyond that inherent in the pattern of racketeering activity in which its members engage?


Opinions:

Majority - Justice Alito

No. An association-in-fact enterprise under RICO must have a structure, but it does not need one that is ascertainable beyond that inherent in the pattern of racketeering activity. The statutory text of RICO is broad and intended to be liberally construed. An enterprise's essential structure consists of three features: 1) a purpose, 2) relationships among those associated with the enterprise, and 3) longevity sufficient to permit these associates to pursue the enterprise’s purpose. The statute does not require more formal attributes such as a hierarchy, a chain of command, fixed roles, a name, or regular meetings. While the existence of an enterprise is a separate element from the pattern of racketeering activity, the evidence used to prove the two elements 'may in particular cases coalesce.' Therefore, a jury can infer the existence of the enterprise from the evidence showing the group's course of conduct and commission of predicate acts.


Dissenting - Justice Stevens

Yes. A RICO enterprise should be a business-like entity with an existence separate and apart from the pattern of criminal acts its members commit. The majority’s holding renders the 'enterprise' element of the offense essentially meaningless, allowing it to merge with the 'pattern of racketeering' element. This conflates the RICO offense with a simple conspiracy to commit predicate acts, expanding RICO liability far beyond what Congress intended. The statute's language and structure suggest that an 'enterprise' requires an organization with affairs that can be directed, which implies a structure more defined than the mere commission of crimes. The group in this case was merely an 'ad hoc association of thieves' and lacked the distinct, ongoing structure required to constitute a RICO enterprise.



Analysis:

This decision significantly broadened the scope of RICO by clarifying that loosely organized criminal groups without a formal hierarchy can constitute an 'association-in-fact enterprise.' By rejecting the requirement for a structure distinct from the pattern of criminal activity, the Court made it easier for prosecutors to bring RICO charges against informal networks. The holding solidifies a functional, rather than formal, definition of a RICO enterprise, focusing on the core elements of purpose, relationships, and continuity. This lowers the evidentiary bar for establishing the 'enterprise' element, as the same evidence of criminal conduct can be used to infer the enterprise's existence.

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