How have courts interpreted "organize" and "manage" terms in section 848 of the Civil Code?
MultiRegion, United States of America
The following excerpt is from U.S. v. Scarpa, 913 F.2d 993 (2nd Cir. 1990):
"The operative concepts used in section 848--'organize,' 'supervise,' and 'manage'--are not technical, and we see no reason to give them other than their everyday meanings." United States v. Mannino, 635 F.2d 110, 117 (2d Cir.1980). Further, a defendant "need not have been the dominant organizer or manager as long as [he] was in some managerial position." United States v. Losada, 674 F.2d 167, 174 (2d Cir.), cert. denied, 457 U.S. 1125, 102 S.Ct. 2945, 73 L.Ed.2d 1341 (1982).
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