Ohio State Journal of Criminal Law

OSJCL Amici Board of Advisors

OSJCL Amici: Views from the Field

Boyle v. United States

  • The argument was heard on January 14, 2009.
  • Issue: The issue in Boyle is whether, under the Racketeer Influenced and Corrupt Organizations Act, an “enterprise” requires the existence of an ascertainable structure.
  • Background: The defendant was convicted of racketeering and conspiracy to commit racketeering, a violation of the RICO Act. At trial, the district court rejected Boye’s request to instruct the jury that an “enterprise” requires “an ongoing organization, a core membership that functioned as a continuing unit, and an ascertainable structural hierarchy.”



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