What is the test for establishing a pattern of criminal activity in violation of RICO and Hobbs Act?

Finally, we find sufficient evidence in the record to support the jury's finding of a "pattern" of racketeering activity. "Racketeering" includes violations of the Hobbs Act, as well as robbery and murder in violation of state law. 18 U.S.C. 1961(1). We have previously held that, in order to satisfy RICO's pattern requirement, the government must establish that two racketeering acts were related to each other and that they resulted in, or posed a threat of, continuing criminal activity. United States v. Indelicato, 865 F.2d 1370, 1381 (2d Cir.) (in banc ), cert. denied, 491 U.S. 907 (1989). Here, the predicate acts--the robberies--were plainly related to one another as well as to the enterprise's common purpose of making money by robbing commercial businesses with large amounts of cash on hand. The crime spree included seven robberies over an eight-month period and clearly it supported an inference of a threat of continuity.

We have considered all of the defendant's other arguments and we find them to be without merit.

The judgment of the district court is affirmed.

1 18 U.S.C. 1962(c) provides in relevant part: