The article discusses the role of Racketeer Influenced and Corrupt Organizations Act (RICO) during criminal proceedings which have both criminal and civil liability for violations of prohibited activities. The U.S. Supreme Court case H.J. Inc. v. Northwestern Bell Telephone Co. in which the Court rejected the Eighth Circuit's requirement of multiple schemes. The U.S. Court of Appeal for the Eighth Circuit held that a single scheme is not sufficient to satisfy the continuity element.
Kevin J. Murphy,
The Resurrection of the Single Scheme Exclusion to Rico's Pattern Requirement,
Notre Dame L. Rev.
Available at: https://scholarship.law.nd.edu/ndlr/vol88/iss4/5