Can a criminal conviction for a prior RICO offence be used as a predicate act in a subsequent RICO case?

United States v. Persico, 774 F.2d 30, 32 (2d Cir.1985), held that offenses to which the defendants in that case had pled guilty in a separate prosecution could be charged as predicate acts in a subsequent prosecution for a RICO offense continuing after the plea to the prior offense. See also Garrett v. United States, 471 U.S. 773, 105 S.Ct. 2407, 85 L.Ed.2d 764 (1985) (same rule as to separate prosecution for engaging in a continuing criminal enterprise extending beyond the plea to the prior offense in violation of 21 U.S.C. Sec. 848). ⁸ Catanzano

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