United States v. Turkette
452 U.S. 576 (1981)
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Rule of Law:
The term "enterprise" as defined in the Racketeer Influenced and Corrupt Organizations Act (RICO), 18 U.S.C. § 1961(4), encompasses both legitimate and wholly illegitimate associations.
Facts:
- Edward Turkette was the alleged leader of a criminal organization.
- The indictment described the organization as a group of individuals associated in fact for several criminal purposes.
- These purposes included illegally trafficking in narcotics and other dangerous drugs, and committing arsons.
- The group also allegedly utilized U.S. mails to defraud insurance companies.
- Additionally, the group's purposes included bribing local police officers and corruptly influencing state court proceedings.
Procedural Posture:
- Edward Turkette and others were charged in a nine-count indictment in a federal district court (the court of first instance).
- Following a jury trial, Turkette was convicted on all nine counts, including the RICO conspiracy count.
- Turkette (as appellant) appealed his conviction to the U.S. Court of Appeals for the First Circuit.
- The Court of Appeals sided with Turkette, holding that RICO applies only to the infiltration of legitimate enterprises, and reversed his RICO conspiracy conviction.
- The United States (as petitioner) was granted a writ of certiorari by the U.S. Supreme Court to resolve a conflict among the Circuit courts on this issue.
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Issue:
Does the term "enterprise" in the Racketeer Influenced and Corrupt Organizations Act (RICO) apply exclusively to legitimate organizations, or does it also encompass associations whose purposes are entirely criminal?
Opinions:
Majority - Justice White
No, the term "enterprise" is not limited to legitimate organizations; it encompasses any group of individuals associated in fact, including those that are exclusively criminal. The plain language of the statute, 18 U.S.C. § 1961(4), defines "enterprise" broadly to include "any union or group of individuals associated in fact although not a legal entity." There is no restrictive language, such as the word "legitimate," limiting the scope of this definition. The court rejected the lower court's reliance on statutory construction rules like ejusdem generis, finding the statutory language unambiguous. Furthermore, the Court clarified that the "enterprise" is a separate element from the "pattern of racketeering activity"; the enterprise is the organizational structure or vehicle, while the pattern is the series of criminal acts it commits. Applying RICO to criminal enterprises serves the statute's broad purpose of eradicating organized crime by striking at its economic source, which often originates from wholly illicit activities.
Dissenting - Justice Stewart
Yes, the term "enterprise" should be limited to legitimate organizations. The dissent simply states its agreement with the reasoning and conclusion of the Court of Appeals, which held that RICO was intended solely to protect legitimate businesses from infiltration by racketeers.
Analysis:
This decision significantly broadened the prosecutorial power of the RICO statute. By confirming that "enterprise" includes purely criminal organizations, the Supreme Court allowed prosecutors to target organized crime groups directly, not just their efforts to infiltrate the legitimate economy. This interpretation established RICO as a primary tool for dismantling criminal syndicates, gangs, and other illicit associations based on their organizational structure and pattern of criminal conduct. It prevents criminal groups from being immune to RICO prosecution simply because they have not yet managed to invest their illegal profits into a legitimate business.
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