What is the current state of the law on racketeering and collection of unlawful debt?

MultiRegion, United States of America

The following excerpt is from Myers v. Encore Credit, No. CIV S-11-1714 KJM KJN (E.D. Cal. 2012):

Under 18 U.S.C. 1962(c), it is unlawful "for any person employed by or associated with any enterprise . . . to conduct or participate, directly or indirectly, in the conduct of such enterprise's affairs through a pattern of racketeering activity or collection of unlawful debt." "Racketeering activity" is defined as any of a number of "generically specified criminal acts as well as the commission of one of a number of listed predicate offenses." Sosa v. DIRECTV, Inc., 437 F.3d 923, 939 (9th Cir. 2006). A "pattern of racketeering activity" requires at least two acts, and an unlawful debt is one stemming from illegal gambling. 18 U.S.C. 1961(1), (5) & (6).

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