What is the test for establishing a "pattern" of criminal activity?
MultiRegion, United States of America
The following excerpt is from U.S. v. Campanale, 518 F.2d 352 (9th Cir. 1975):
The concept "pattern" is thought to provide no due process constitutional barrier to criminal sanctions, as a "racketeering activity," defined above, must be an act in itself subject to criminal sanction and any proscribed act in the pattern must violate an independent statute. See United States v. Nardello, 393 U.S. 286, 89 S.Ct. 534, 21 L.Ed.2d 487 (1969).
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