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defendantattorneyappealtrialpiracy
defendantstatuteappealcommon lawappellantpiracy

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U.S. v. Teitler, 802 F.2d 606, RICO Bus.Disp.Guide 6395

Facts

The indictment alleged that a law firm in Queens County, New York, defrauded insurance companies by manipulating claims from automobile accidents. Attorneys Jay Teitler and Marc Schultz were involved in creating false documents and encouraging perjury to inflate claims. The firm exploited New York's no-fault insurance law, leading to multiple counts of racketeering, including mail fraud and obstruction of justice. Evidence presented at trial included testimonies from clients and former employees detailing the fraudulent practices employed by the firm.

Over a number of years, according to the indictment, a law firm in Queens County, New York, defrauded insurance companies by manipulating claims arising out of automobile accidents.

Issue

The main legal issues included whether the evidence was sufficient to support the RICO conspiracy convictions and whether the charges against the defendants were properly joined.

Novel questions are raised concerning the interpretation of the meaning of 'pattern' as described in the RICO statute as well as the applicability of common law conspiracy rules to RICO conspiracies.

Rule

The court applied the legal principles of RICO, which require proof of a pattern of racketeering activity, and clarified that a RICO conspiracy conviction does not necessitate the actual commission of predicate acts, only an agreement to commit them.

A pattern of racketeering activity is committed if the Defendant committed at least two of the racketeering acts charged against him or her in the indictment….

Analysis

The court found that the evidence presented at trial was sufficient to establish that both defendants agreed to commit at least two predicate acts as part of a RICO conspiracy. The jury was properly instructed that they could convict based on the agreement to commit the acts, even if they did not find that the acts were actually carried out. The court also determined that the charges against the defendants were appropriately joined, as they were part of the same series of transactions constituting the RICO enterprise.

The evidence showed that both of the acts of racketeering charged against the appellant had a similar purpose, namely, defrauding insurance companies; both shared similar success in defrauding such companies; both shared similar participants and similar victims; and both employed similar methods.

Conclusion

The Court of Appeals affirmed the convictions of both defendants, concluding that the evidence supported the jury's findings and that the trial court's instructions were appropriate.

Affirmed.

Who won?

The United States prevailed in the case, as the court upheld the convictions of the defendants based on sufficient evidence of their involvement in a RICO conspiracy and mail fraud.

The Court of Appeals, Pierce, Circuit Judge, held that: (1) there was ample evidence from which jury could find that the two predicate acts one defendant agreed to perform were part of a RICO pattern for purposes of a conspiracy to conduct the affairs of the law firm through pattern of racketeering activity by manipulating claims arising out of automobile accidents.

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