The Racketeer Influenced and Corrupt Organizations Act (RICO)2 has produced a complex body of law. One area within the Act, conspiracy to violate the substantive provisions of RICO under Section 1962(d), has produced contrary views in the federal courts of appeals as to whether one must agree to personally commit the illegal, predicate acts, or whether one need only agree that another member of the conspiracy commit the acts. The United States Supreme Court has now settled the debate over this issue by holding that one need only agree that some member of the enterprise will commit the predicate act

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