Criminal Law Keyed to Bonnie
Boyle v. United States
Facts
Boyle was involved in a group engaged in a series of bank robberies. The group was loosely organized and did not designate roles in the group. Boyle was charged with violating the Racketeering Influence and Corrupt Organizations Act (RICO Act), 18 U.S.C. § 1963(c), which made it unlawful for a person to engage in collective “enterprise” that involves racketeering and affects interstate or foreign commerce. Without a statutory definition of “enterprise”, the district court defined an enterprise as a structure which is loosely organized for the purpose of engaging in racketeering and that an association-in-fact structure is defined by the activities it is engaged in. The jury convicted Boyle for violating the RICO Act and the Second Circuit Court of Appeals affirmed.
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