Supreme Court of the United States · 1994-01-24
18usc1962: author: Fable · historical QA: FIX (QA2, neov2/qa/cases-QA2.md) · changed after review; current content not independently reviewed
Case and law context
Role: rule-announced; posture: civil; Rule 12(b)(6) dismissal affirmed by CA7 for want of an economic motive; certiorari on whether the enterprise or the predicate acts must have an economic purpose; result: remanded; claim: (c),(d)
Uncertainty
None recorded
Misfit
The holding is the ABSENCE of a requirement (no economic motive for either the enterprise or the predicate acts): one negative rule about several elements at once. v1 records it as three rule-announced, not-reached blocks (enterprise, commerce, racketeering.extortion); the .law side has a `not-required` line for it, but a .case block still cannot say "element X does not require property Y" or point at that line.
Article III standing is recorded under `injury` with `scope procedural`, which keeps it out of the instance count; the id still names the §1964(c) "business or property" element, which the Court did not address (an x-standing id would be more honest).
First Amendment limits (majority fn. declining to reach; Souter/Kennedy concurrence saying it remains an as-applied defense) are a potential `defense` that was raised but expressly not decided; no way to record an undecided defense except a bare line.
The enterprise plays a different ROLE per subsection (vehicle in (c); prize/victim in (a),(b)) and the rule depends on that role; the .law file now states this as constraint enterprise-role-by-subsection, but a .case block has one `enterprise` id for all subsections and cannot reference a constraint.
B · Case × element grid
Top-level elements follow claim order in panels of up to six elements. Case rows repeat across panels. Every recorded block retains its holding and basis; multiple blocks are not merged into a case-level verdict. ✓ satisfied · ✗ not satisfied · ○ not reached · · not addressed. Muted blocks are not counted. Sub-element evidence remains on case and element pages.
Elements 1–6 of 19
| Case | Culpable person (§ 1961(3)) distinct from the enterprise under (c) | Pattern of racketeering activity (§ 1961(5)): at least two predicate acts with relatedness and continuity | Racketeering activity (§ 1961(1) enumerated state and federal predicate offenses) | Collection of an unlawful debt (§ 1961(6)) — alternative to pattern of racketeering activity | Use or investment of racketeering income in an enterprise (§ 1962(a)) | Enterprise (§ 1961(4)): legal entity or association-in-fact |
|---|---|---|---|---|---|---|
| National Organization for Women, Inc. v. Scheidler — 510 U.S. 249 (1994) · Supreme Court of the United States · 1994 (18usc1962: author: Fable · historical QA: FIX (QA2, neov2/qa/cases-QA2.md) · changed after review; current content not independently reviewed) | · not addressed | ○ not reached · basis not recordedNot counted: background/merits | · not addressed | · not addressed | ○ not reached · basis not recordedNot counted: rule-announced/merits | ○ not reached · basis not recordedNot counted: rule-announced/merits |
Elements 7–12 of 19
| Case | Interstate or foreign commerce nexus | De minimis open-market securities investment proviso (§ 1962(a)) | Acquire or maintain interest in or control of an enterprise (§ 1962(b)) | Defendant employed by or associated with the enterprise (§ 1962(c)) | Conduct or participate in the conduct of enterprise affairs (§ 1962(c) operation or management test) | Conspiracy to violate § 1962(a), (b), or (c) (§ 1962(d)) |
|---|---|---|---|---|---|---|
| National Organization for Women, Inc. v. Scheidler — 510 U.S. 249 (1994) · Supreme Court of the United States · 1994 (18usc1962: author: Fable · historical QA: FIX (QA2, neov2/qa/cases-QA2.md) · changed after review; current content not independently reviewed) | ○ not reached · basis not recordedNot counted: rule-announced/merits | · not addressed | · not addressed | · not addressed | ○ not reached · basis not recordedNot counted: rule-announced/merits | ○ not reached · basis not recordedNot counted: rule-announced/merits |
Elements 13–18 of 19
| Case | Civil RICO injury to business or property (18 U.S.C. § 1964(c)) | But-for and proximate causation ("by reason of", 18 U.S.C. § 1964(c)) | Statute of limitations (4-year civil under Agency Holding; 5-year criminal under 18 U.S.C. § 3282) | Claim preclusion / release by prior class-action settlement | Civil aiding and abetting a RICO violation (rejected as a private cause of action) | Fifth Amendment Double Jeopardy bar against successive RICO conspiracy/substantive prosecutions |
|---|---|---|---|---|---|---|
| National Organization for Women, Inc. v. Scheidler — 510 U.S. 249 (1994) · Supreme Court of the United States · 1994 (18usc1962: author: Fable · historical QA: FIX (QA2, neov2/qa/cases-QA2.md) · changed after review; current content not independently reviewed) | ✓ satisfied · pleadedNot counted: applied/procedural | · not addressed | · not addressed | · not addressed | · not addressed | · not addressed |
Elements 19–19 of 19
| Case | Parol evidence rule raised to bar extrinsic evidence of fraudulent misrepresentations |
|---|---|
| National Organization for Women, Inc. v. Scheidler — 510 U.S. 249 (1994) · Supreme Court of the United States · 1994 (18usc1962: author: Fable · historical QA: FIX (QA2, neov2/qa/cases-QA2.md) · changed after review; current content not independently reviewed) | · not addressed |
Instances and excluded annotation blocks
| Case | Element | Holding and scope | Pattern | Exact source quotations |
|---|---|---|---|---|
| National Organization for Women, Inc. v. Scheidler — 510 U.S. 249 (1994) · Supreme Court of the United States · 1994 — not reached (18usc1962: author: Fable · historical QA: FIX (QA2, neov2/qa/cases-QA2.md) · changed after review; current content not independently reviewed) | Interstate or foreign commerce nexus | not_reached Excluded from merits counts rule-announced / merits claim: (c),(d) "Affect" commerce includes harming the commerce of others (the clinics); the commerce clause of (c) does not smuggle in an economic-motive requirement. Whether the commerce nexus is actually met was not separately decided. | affects-commerce/detrimental-effect-without-profit-motive | Petitioners alleged that respondents conspired to use threatened or actual force, violence, or fear to induce clinic employees, doctors, and patients to give up their jobs, give up their economic right to practice medicine, and give up their right to obtain medical services at the clinics.Source: docroot/ir/caselaw/us_510.jsonl#/us/510/0249-01; Unicode character offsets [2871:3161] (end exclusive); SHA-256 cb4e617ad929914e8013956e456c6d025b7f974213b9a4c541b1fdd0f9d49931.An enterprise surely can have a detrimental influence on interstate or foreign commerce without having its own profit-seeking motives.Source: docroot/ir/caselaw/us_510.jsonl#/us/510/0249-01; Unicode character offsets [9808:9942] (end exclusive); SHA-256 cb4e617ad929914e8013956e456c6d025b7f974213b9a4c541b1fdd0f9d49931. |
| National Organization for Women, Inc. v. Scheidler — 510 U.S. 249 (1994) · Supreme Court of the United States · 1994 — not reached (18usc1962: author: Fable · historical QA: FIX (QA2, neov2/qa/cases-QA2.md) · changed after review; current content not independently reviewed) | Conduct or participate in the conduct of enterprise affairs (§ 1962(c) operation or management test) | not_reached Excluded from merits counts rule-announced / merits claim: (c),(d) | Unspecified route | No source quotation recorded for this block. |
| National Organization for Women, Inc. v. Scheidler — 510 U.S. 249 (1994) · Supreme Court of the United States · 1994 — not reached (18usc1962: author: Fable · historical QA: FIX (QA2, neov2/qa/cases-QA2.md) · changed after review; current content not independently reviewed) | Conspiracy to violate § 1962(a), (b), or (c) (§ 1962(d)) | not_reached Excluded from merits counts rule-announced / merits claim: (c),(d) (d) claim was dismissed below only because the substantive claims fell; revived by the reversal without separate analysis. | Unspecified route | No source quotation recorded for this block. |
| National Organization for Women, Inc. v. Scheidler — 510 U.S. 249 (1994) · Supreme Court of the United States · 1994 — not reached (18usc1962: author: Fable · historical QA: FIX (QA2, neov2/qa/cases-QA2.md) · changed after review; current content not independently reviewed) | Enterprise (§ 1961(4)): legal entity or association-in-fact | not_reached Excluded from merits counts rule-announced / merits claim: (c),(d); party: Pro-Life Action Network (PLAN), a coalition of antiabortion groups; subject: party=Pro-Life Action Network (PLAN), a coalition of antiabortion groups Politically/ideologically motivated group with no profit-seeking purpose can be a (c) enterprise; the enterprise under (c) is the "vehicle", not the "victim" or "prize" as under (a)/(b). Was `satisfied [law]`: the Court held only that no economic motive is required and reversed a 12(b)(6) dismissal resting on that supposed requirement; whether PLAN is an enterprise in any other respect was not adjudicated. | non-economic-advocacy-coalition | Respondents are a coalition of antiabortion groups called the Pro-Life Action Network (PLAN), Joseph Scheidler and other individuals and organizations that oppose legal abortion, and a medical laboratory that formerly provided services to the two petitioner health care centers.Source: docroot/ir/caselaw/us_510.jsonl#/us/510/0249-01; Unicode character offsets [1051:1329] (end exclusive); SHA-256 cb4e617ad929914e8013956e456c6d025b7f974213b9a4c541b1fdd0f9d49931.The amended complaint alleged that respondents were members of a nationwide conspiracy to shut down abortion clinics through a pattern of racketeering activity including extortion in violation of the Hobbs Act, 18 U. S. C. § 1951.Source: docroot/ir/caselaw/us_510.jsonl#/us/510/0249-01; Unicode character offsets [2432:2662] (end exclusive); SHA-256 cb4e617ad929914e8013956e456c6d025b7f974213b9a4c541b1fdd0f9d49931.According to the amended complaint, PLAN constitutes the alleged racketeering “enterprise” for purposes of § 1962(c).Source: docroot/ir/caselaw/us_510.jsonl#/us/510/0249-01; Unicode character offsets [3337:3454] (end exclusive); SHA-256 cb4e617ad929914e8013956e456c6d025b7f974213b9a4c541b1fdd0f9d49931.Consequently, since the enterprise in subsection (c) is not being acquired, it need not have a property interest that can be acquired nor an economic motive for engaging in illegal activity; it need only be an association in fact that engages in a pattern of racketeering activity.Source: docroot/ir/caselaw/us_510.jsonl#/us/510/0249-01; Unicode character offsets [12588:12869] (end exclusive); SHA-256 cb4e617ad929914e8013956e456c6d025b7f974213b9a4c541b1fdd0f9d49931.Congress has not, either in the definitional section or in the operative language, required that an “enterprise” in § 1962(c) have an economic motive.Source: docroot/ir/caselaw/us_510.jsonl#/us/510/0249-01; Unicode character offsets [15516:15666] (end exclusive); SHA-256 cb4e617ad929914e8013956e456c6d025b7f974213b9a4c541b1fdd0f9d49931.We hold only that RICO contains no economic motive requirement.Source: docroot/ir/caselaw/us_510.jsonl#/us/510/0249-01; Unicode character offsets [18463:18526] (end exclusive); SHA-256 cb4e617ad929914e8013956e456c6d025b7f974213b9a4c541b1fdd0f9d49931. |
| National Organization for Women, Inc. v. Scheidler — 510 U.S. 249 (1994) · Supreme Court of the United States · 1994 — satisfied · pleaded (18usc1962: author: Fable · historical QA: FIX (QA2, neov2/qa/cases-QA2.md) · changed after review; current content not independently reviewed) | Civil RICO injury to business or property (18 U.S.C. § 1964(c)) | satisfied Excluded from merits counts applied / procedural basis: pleaded; claim: (c),(d); party: DWHO and SWHO (the clinics); NOW itself did not sue under RICO; subject: party=DWHO and SWHO (the clinics); NOW itself did not sue under RICO Decided as Article III standing (injury fairly traceable), not as the §1964(c) "business or property" element as such; recorded here because the same allegation serves both. | business-injury/clinic-operations-disrupted-by-threats | DWHO and SWHO alleged in their complaint that respondents conspired to use force to induce clinic staff and patients to stop working and obtain medical services elsewhere.Source: docroot/ir/caselaw/us_510.jsonl#/us/510/0249-01; Unicode character offsets [7474:7645] (end exclusive); SHA-256 cb4e617ad929914e8013956e456c6d025b7f974213b9a4c541b1fdd0f9d49931.Petitioners claimed that this conspiracy “has injured the business and/or property interests of the [petitioners].”Source: docroot/ir/caselaw/us_510.jsonl#/us/510/0249-01; Unicode character offsets [7686:7801] (end exclusive); SHA-256 cb4e617ad929914e8013956e456c6d025b7f974213b9a4c541b1fdd0f9d49931.The District Court dismissed petitioners’ claim at the pleading stage pursuant to Federal Rule of Civil Procedure 12(b)(6), so their complaint must be sustained if relief could be granted “under any set of facts that could be proved consistent with the allegations.”Source: docroot/ir/caselaw/us_510.jsonl#/us/510/0249-01; Unicode character offsets [7155:7421] (end exclusive); SHA-256 cb4e617ad929914e8013956e456c6d025b7f974213b9a4c541b1fdd0f9d49931.Nothing more is needed to confer standing on DWHO and SWHO at the pleading stage.Source: docroot/ir/caselaw/us_510.jsonl#/us/510/0249-01; Unicode character offsets [8122:8203] (end exclusive); SHA-256 cb4e617ad929914e8013956e456c6d025b7f974213b9a4c541b1fdd0f9d49931. |
| National Organization for Women, Inc. v. Scheidler — 510 U.S. 249 (1994) · Supreme Court of the United States · 1994 — not reached (18usc1962: author: Fable · historical QA: FIX (QA2, neov2/qa/cases-QA2.md) · changed after review; current content not independently reviewed) | Use or investment of racketeering income in an enterprise (§ 1962(a)) | not_reached Excluded from merits counts rule-announced / merits claim: (c),(d) (a) claim dismissed below (donations were not income derived from the alleged racketeering); certiorari covered only (c) and (d). | Unspecified route | No source quotation recorded for this block. |
| National Organization for Women, Inc. v. Scheidler — 510 U.S. 249 (1994) · Supreme Court of the United States · 1994 — not reached (18usc1962: author: Fable · historical QA: FIX (QA2, neov2/qa/cases-QA2.md) · changed after review; current content not independently reviewed) | Pattern of racketeering activity (§ 1961(5)): at least two predicate acts with relatedness and continuity | not_reached Excluded from merits counts background / merits claim: (c),(d) | Unspecified route | The questions whether respondents committed the requisite predicate acts, and whether the commission of these acts fell into a pattern, are not before us.Source: docroot/ir/caselaw/us_510.jsonl#/us/510/0249-01; Unicode character offsets [18308:18462] (end exclusive); SHA-256 cb4e617ad929914e8013956e456c6d025b7f974213b9a4c541b1fdd0f9d49931. |
| National Organization for Women, Inc. v. Scheidler — 510 U.S. 249 (1994) · Supreme Court of the United States · 1994 — not reached (18usc1962: author: Fable · historical QA: FIX (QA2, neov2/qa/cases-QA2.md) · changed after review; current content not independently reviewed) | Hobbs Act or state-law extortion predicate (18 U.S.C. § 1951; § 1961(1)(A),(B)) | not_reached Excluded from merits counts rule-announced / merits claim: (c),(d) Only decided: predicate acts need no economic motive. Whether the conduct is Hobbs Act extortion ("obtaining of property") was expressly reserved. | hobbs-act-extortion/non-economic-motive | In addition, petitioners claimed that respondent Scheidler threatened DWHO’s clinic administrator with reprisals if she refused to quit her job at the clinic.Source: docroot/ir/caselaw/us_510.jsonl#/us/510/0249-01; Unicode character offsets [7821:7979] (end exclusive); SHA-256 cb4e617ad929914e8013956e456c6d025b7f974213b9a4c541b1fdd0f9d49931.predicate acts, such as the alleged extortion, may not benefit the protesters financially but still may drain money from the economy by harming businesses such as the clinics which are petitioners in this caseSource: docroot/ir/caselaw/us_510.jsonl#/us/510/0249-01; Unicode character offsets [13786:13995] (end exclusive); SHA-256 cb4e617ad929914e8013956e456c6d025b7f974213b9a4c541b1fdd0f9d49931.Respondents contend that petitioners are unable to show that their actions violated the Hobbs Act. We do not reach that issue and express no opinion upon it.Source: docroot/ir/caselaw/us_510.jsonl#/us/510/0249-01; Unicode character offsets [19379:19536] (end exclusive); SHA-256 cb4e617ad929914e8013956e456c6d025b7f974213b9a4c541b1fdd0f9d49931. |
Court interpretations recorded from this case
interpretation
Congress has not, either in the definitional section or in the operative language, required that an “enterprise” in § 1962(c) have an economic motive.
National Organization for Women, Inc. v. Scheidler — 510 U.S. 249 (1994) · Supreme Court of the United States · 1994 (18usc1962: author: Fable · historical QA: FIX (QA2, neov2/qa/cases-QA2.md) · changed after review; current content not independently reviewed)
Congress has not, either in the definitional section or in the operative language, required that an “enterprise” in § 1962(c) have an economic motive.Source:
docroot/ir/caselaw/us_510.jsonl#/us/510/0249-01; Unicode character offsets [15516:15666] (end exclusive); SHA-256 cb4e617ad929914e8013956e456c6d025b7f974213b9a4c541b1fdd0f9d49931.Turkette and Boyle govern association-in-fact enterprises: purpose + relationships among associates + longevity sufficient to pursue the purpose.
interpretation
An enterprise surely can have a detrimental influence on interstate or foreign commerce without having its own profit-seeking motives.
National Organization for Women, Inc. v. Scheidler — 510 U.S. 249 (1994) · Supreme Court of the United States · 1994 (18usc1962: author: Fable · historical QA: FIX (QA2, neov2/qa/cases-QA2.md) · changed after review; current content not independently reviewed)
An enterprise surely can have a detrimental influence on interstate or foreign commerce without having its own profit-seeking motives.Source:
docroot/ir/caselaw/us_510.jsonl#/us/510/0249-01; Unicode character offsets [9808:9942] (end exclusive); SHA-256 cb4e617ad929914e8013956e456c6d025b7f974213b9a4c541b1fdd0f9d49931.A de minimis effect on interstate commerce by the enterprise's activities (including detrimental effects on victims engaged in commerce) suffices.
interpretation
Consequently, since the enterprise in subsection (c) is not being acquired, it need not have a property interest that can be acquired nor an economic motive for engaging in illegal activity; it need only be an association in fact that engages in a pattern of racketeering activity.
National Organization for Women, Inc. v. Scheidler — 510 U.S. 249 (1994) · Supreme Court of the United States · 1994 (18usc1962: author: Fable · historical QA: FIX (QA2, neov2/qa/cases-QA2.md) · changed after review; current content not independently reviewed)
Consequently, since the enterprise in subsection (c) is not being acquired, it need not have a property interest that can be acquired nor an economic motive for engaging in illegal activity; it need only be an association in fact that engages in a pattern of racketeering activity.Source:
docroot/ir/caselaw/us_510.jsonl#/us/510/0249-01; Unicode character offsets [12588:12869] (end exclusive); SHA-256 cb4e617ad929914e8013956e456c6d025b7f974213b9a4c541b1fdd0f9d49931.Under § 1962(b), the acquisition or maintenance of interest/control in the enterprise must occur *through* the pattern of racketeering activity or unlawful debt collection, and civil plaintiffs must show "acquisition injury" distinct from predicate-act injury.
interpretation
Consequently, since the enterprise in subsection (c) is not being acquired, it need not have a property interest that can be acquired nor an economic motive for engaging in illegal activity; it need only be an association in fact that engages in a pattern of racketeering activity.
National Organization for Women, Inc. v. Scheidler — 510 U.S. 249 (1994) · Supreme Court of the United States · 1994 (18usc1962: author: Fable · historical QA: FIX (QA2, neov2/qa/cases-QA2.md) · changed after review; current content not independently reviewed)
Consequently, since the enterprise in subsection (c) is not being acquired, it need not have a property interest that can be acquired nor an economic motive for engaging in illegal activity; it need only be an association in fact that engages in a pattern of racketeering activity.Source:
docroot/ir/caselaw/us_510.jsonl#/us/510/0249-01; Unicode character offsets [12588:12869] (end exclusive); SHA-256 cb4e617ad929914e8013956e456c6d025b7f974213b9a4c541b1fdd0f9d49931.The enterprise is the "prize" or "victim" acquired or invested in under (a) and (b), but is the "vehicle" through which unlawful activity is conducted under (c).