RICO Enterprise — Is an Ascertainable Structure Required?

Yes: 3d Circuit, 4th Circuit, 8th Circuit, and 10th Circuit

No: 1st Circuit, 2d Circuit, 9th Circuit, 11th Circuit, and D.C. Circuit

Sort of: 7th Circuit

As Justice Scalia once observed about the Supreme Court's enterprise test: "This seems to me about as helpful to the conduct of [the lower courts'] as 'life is a fountain.'" H. J. Inc. v. Northwestern Bell Tel. Co., 492 U.S. 229, 252 (1989)

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