The National Organization for Women (NOW) sued a coalition of anti-abortion groups called the Pro-Life Action Network (PLAN) under the Racketeer Influenced and Corrupt Organizations (RICO) Act. N.O.W. alleged that Scheidler and other anti-abortion protesters were members in a nationwide conspiracy to obstruct women's access to abortion clinics through a pattern of racketeering activity including the actual or implied threat of violence. The District Court dismissed the suit, holding that the voluntary contributions are not proceeds of racketeering and that a "racketeering enterprise" must have an economic motive, a fact that NOW could not demonstrate. The Court of Appeals affirmed and the Supreme Court granted certiorari.
Does RICO require that an organization, to be defined as a racketeering enterprise, must be acting in pursuit of an economic motive?
The unanimous Court held that organizations without an economic motive can detrimentally "affect interstate or foreign commerce," satisfying the RICO definition of a racketeering enterprise. An "enterprise" does not have to be an economic organization or a principally criminal organization to trigger the RICO act. Consequently, the Court reversed the appeals court decision which allowed the original case to proceed.
Decisions
Decision: 9 votes for National Organization for Women (NOW), 0 vote(s) against Legal provision: Racketeer Influenced and Corrupt Organizations
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Full Opinion by Justice William H. Rehnquist
