United States v. Robertson
Headline: Court upholds RICO conviction by finding an Alaska gold mine engaged in interstate commerce through out-of-state equipment purchases, hired workers, and gold transported across state lines.
Holding: In reversing the Ninth Circuit, the Court held that Robertson’s Alaska gold mine was "engaged in interstate commerce" under RICO because of out-of-state equipment purchases, hired non‑Alaska workers, and gold shipped out of state.
- Makes it easier to apply RICO when businesses buy equipment from other states.
- Counts out-of-state hires and shipping gold across state lines as interstate activity.
- Reverses appeals court and lets the RICO conviction stand based on interstate ties.
Summary
Background
Juan Paul Robertson, who lived in Arizona, was charged with drug offenses and with a racketeering charge for investing drug money in an Alaska gold mine. He bought mining claims, spent about $100,000 on equipment and supplies (some bought in Los Angeles and shipped to Alaska), and paid out-of-state workers to come to Alaska. The mine produced roughly $200,000–$290,000 in gold, and Robertson personally took about $30,000 of that gold out of the State. A federal appeals court had reversed the racketeering conviction for lack of evidence that the mine affected interstate trade.
Reasoning
The Court focused on whether the mine itself was engaged in interstate commerce. It pointed to proved facts: significant out-of-state purchases used in the mine, recruitment and payment of workers from other States, and the owner’s transport of gold out of Alaska. The Justices explained that those direct cross-state activities bring the mine within the law’s alternative phrase covering enterprises “engaged in interstate commerce.” Because of those interstate ties, the Court reversed the appeals court and allowed the racketeering conviction to stand.
Real world impact
The decision shows that a business can fall under federal racketeering rules when it itself buys goods from other States, brings in out-of-state labor, or moves product across state lines. The Court did not decide whether purely local activities that only "affect" interstate commerce would meet the law’s other test, so that separate question remains open.
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