Pattern Element Is Still Crucial To Defending RICO Cases
As the U.S. Supreme Court said more than 30 years ago in Agency Holding Corp. v. Malley-Duff and Associates Inc., "[T]he heart of any RICO complaint is the allegation of pattern of racketeering." Agency Holding was one of a long line of cases exploring the pattern element. The statement holds true today: The pattern element remains the proverbial heart of the beast that is the Racketeer Influenced and Corrupt Organizations Act.
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