United States v. Aulicino
United States Court of Appeals for the Second Circuit
44 F.3d 1102 (2d Cir. 1995)
Aulicino, Cleary, and Ruggiero (defendants) belonged to a kidnapping ring that identified ten targets and attempted seven kidnappings over roughly three-and-a-half months, murdering one victim whose family refused ransom, torturing and shooting another, and continuing extortion attempts even against a victim who escaped, before the ring ceased operations following its leader's death; Cleary and Ruggiero were convicted under RICO and appealed, arguing their short-duration activities could not establish the required pattern or threat of continuity.
Whether proof of a threat of continuity arising from criminal racketeering acts may be established by short-term criminal enterprises.