Boyle v. United States
United States Supreme Court
556 U.S. 938 (2009)
Boyle (defendant) belonged to a loosely organized crew that committed a series of bank robberies, informally assigning roles like driver or lookout on an ad hoc basis with no fixed leader or hierarchy. He was convicted of violating RICO, and the trial judge instructed the jury that it could find an "enterprise" existed based on the group's pattern of criminal acts alone, without requiring proof of formal structure. Boyle appealed his conviction, arguing this instruction improperly defined "enterprise" too loosely, and the Second Circuit affirmed before the Supreme Court granted certiorari.
Whether, under the RICO Act, an association-in-fact enterprise must have an ascertainable structure beyond that inherent in its own pattern of racketeering activity.