Boyle v. United States

Brief Fact Summary.

Boyle was convicted for violating the Racketeering Influence and Corrupt Organizations Act (RICO Act), 18 U.S.C. § 1963(c) when he engaged in a series of bank robberies with an enterprise with loosely-defined roles.

Synopsis of Rule of Law.

Under the Racketeering Influence and Corrupt Organizations Act (RICO Act), 18 U.S.C. § 1963(c), an association-in-fact enterprise must have a delineated structure, but proof of that structure outside of it’s racketeering activities is not necessary.

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.

Issue.

Whether an association-in-fact enterprise must have a delineated structure outside of it’s racketeering activities as defined by the Racketeering Influence and Corrupt Organizations Act (RICO Act), 18 U.S.C. § 1963(c)?

Held.

No. Decision of the court of appeals is affirmed.

Dissent.

(Stevens, J.) Under the RICO Act, an association-in-fact enterprise is interpreted to be a business-like activity with formal structure. The majority’s decision misinterprets the meaning of enterprise under the RICO Act because it allows the jury to establish the existence of an enterprise through the presence of racketeering activity.

Discussion.

It is sufficient for an association-in-fact enterprise to have a series of activities that achieve a common purpose rather than having designated roles. The district court was correct in it’s analysis of the association-in-fact enterprise, stating that the enterprise must be evaluated by what it does rather than the association’s structure. Under the RICO Act, an association-in-fact enterprise need not have designated roles.