By: Derek Hawkins//August 8, 2016//
7th Circuit court of Appeals
Case Name: Empress Casino Joliet Corp., et al v. Balmoral Racing Club, Inc. et al.
Case No.: 15-2526
Officials: WOOD, Chief Judge, and WILLIAMS and HAMILTON, Circuit Judges.
Focus: RICO
Jury did not have legally sufficient evidence to support RICO verdict.
“Continuity is “centrally a temporal concept.” Id. at 242. The continuity requirement ensures that RICO targets “long‐ term criminal conduct,” one classic example being a protection racket, in which a criminal extracts monthly “insurance” payments from businesses. Id.; see also Gamboa v. Velez, 457 F.3d 703, 705 (7th Cir. 2006) (“RICO, nonetheless, does not cover all instances of wrongdoing. Rather, it is a unique cause of action that is concerned with eradicating organized, long‐ term, habitual criminal activity.”). Continuity limits RICO to schemes meant to exist over a period of time, not one‐off crimes.”
Affirmed in part
Reversed in part