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United States v. Turkette

    Brief Fact Summary.

    Turkette appealed his conviction under the RICO act claiming that the statute only applied to legitimate businesses, not illegal criminal networks.

    Synopsis of Rule of Law.

    The term “enterprise” under RICO applies to illegal criminal networks and legitimate businesses equally.

    Facts.

    Turkette and other accomplices were indicted under the Racketeering Influence and Corrupt Organizations Act (RICO) due to being part of a criminal networks that distributed narcotics. Turkette appealed his conviction claiming that the RICO act only applied to legitimate businesses, and the court of appeals agreed with Turkette. The United States Supreme Court granted certiorari.

    Issue.

    Whether the term “enterprise” under RICO applies to illegal criminal networks and legitimate businesses equally.

    Held.

    Yes. The judgment of the court of appeals is reversed. Turkette and his twelve accomplice joined forces to distribute illicit narcotics throughout the United States.

    Discussion.

    Under the RICO Act, an enterprise is defined as any group of people who come together to participate in illegal activities. Criminal networks fit within the definition of enterprise under the RICO act. The enterprise need not be legal for RICO to apply.


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