United States v. Turkette
Headline: RICO’s definition of “enterprise” is broadened to include groups formed solely to commit crimes, allowing federal prosecutors to use RICO against purely criminal organizations as well as legitimate businesses.
Holding:
- Allows prosecutors to apply RICO to purely criminal groups.
- Makes it easier to target organized crime’s illegal revenue networks.
- Affirms federal reach over criminal enterprises involved in drug and loan-sharking schemes.
Summary
Background
A man (the respondent) and 12 others were indicted on nine counts, including a RICO conspiracy accusing them of running an organization that trafficked drugs, committed arson, insurance fraud, bribery, and other crimes. After a six-week jury trial he was convicted on all counts and received multi-year prison sentences and fines. On appeal he argued RICO was meant only to protect legitimate businesses from infiltration by racketeers.
Reasoning
The question the Court decided was whether the word “enterprise” in the RICO law covers only lawful businesses or also groups that exist purely to commit crimes. The Court examined the statute’s wording — especially the definition that includes “any union or group of individuals associated in fact” — and concluded Congress did not limit “enterprise” to legitimate businesses. The Court rejected the appeals court’s reliance on a narrow reading and found arguments about internal inconsistencies, civil remedies, and federal-state balance unpersuasive. The Court relied on the statute’s language and the Act’s purpose to combat organized crime, and reversed the Court of Appeals’ narrower interpretation.
Real world impact
The ruling confirms that federal prosecutors may use RICO against organizations formed solely to commit crimes, not just those that infiltrate lawful businesses. That means activities Congress listed — like loan sharking, illegal gambling, and drug distribution — can be addressed under RICO when the necessary elements are shown. The decision resolves a split among appellate courts and restores the broader application of the law.
Dissents or concurrances
Justice Stewart disagreed and would have adopted the narrower view of “enterprise” advanced by the Court of Appeals.
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