Boyle v. United States (2008)
- Docket
- 07-1309
- Decided
- 2008-01-01
Summary
Question: In order prove the association of enterprises in a criminal activity, does the government need to show connections between the enterprises beyond what is apparent in the criminal activity itself? Conclusion: No. The Supreme Court held that, under RICO, the association between criminal enterprises must be shown to have a "structure," but the relevant jury instructions need not spell out the precise elements which need be found. With Justice Samuel A. Alito writing for the majority and joined by Chief Justice John G. Roberts, and Justices Antonin G. Scalia, Anthony M. Kennedy, David H. Souter, Clarence Thomas, and Ruth Bader Ginsburg, the Court reasoned that a jury need not be instructed to find an "ascertainable structure" in order to find the association of enterprises because such instructions would be redundant as the jury is already tasked with finding the elements of a crime beyond a reasonable doubt from which it may infer a "structure" of criminal association. Justice John Paul Stevens dissented and was joined by Justice Stephen G. Breyer. He argued that Congress merely intended RICO to apply to "business-like entities," and thus the majority's ruling extended RICO liability far beyond Congress' intent.