## Facts

- National Organization for Women, Inc. (NOW) and two abortion-providing health centers sued Joseph Scheidler and affiliated anti-abortion individuals and groups, including the Pro-Life Action Network (PLAN).
- Plaintiffs alleged a nationwide effort to shut down abortion clinics through threatened or actual force, violence, or fear directed at clinics, staff, physicians, and patients.
- Plaintiffs claimed defendants sought to induce employees and doctors to leave their jobs and to deter patients from obtaining clinic services.
- The complaint alleged injury to plaintiffs’ business and property interests and characterized PLAN as a RICO “enterprise.”
- Plaintiffs asserted claims under the Sherman Act and under RICO §§ 1962(a), 1962(c), and 1962(d), seeking injunctive relief, treble damages, costs, and attorneys’ fees.

## Issues

1. Whether the plaintiffs adequately alleged standing to sue under civil RICO at the motion-to-dismiss stage based on alleged extortion and injury to business or property.
2. Whether RICO § 1962(c) requires proof that either the alleged enterprise or the predicate racketeering acts were motivated by an economic (profit-seeking) purpose.

## Decision

- The Supreme Court unanimously reversed the Seventh Circuit and remanded.
- The Court held that the plaintiffs’ allegations of extortion and injury to business or property were sufficient to establish civil RICO standing at the pleading stage.
- The Court held that RICO does not require an economic motive for the enterprise or for the predicate acts under § 1962(c).
- The Court did not determine whether defendants in fact committed extortion or other RICO predicate offenses; it addressed only the pleading-stage legal questions presented.

## Legal Principles

- RICO § 1962(c), read with § 1961’s definitions, does not impose an economic-motive requirement on either the “enterprise” element or the “pattern of racketeering activity.”
- An association-in-fact group may qualify as a RICO enterprise even if it pursues ideological aims rather than profit, so long as it is engaged in, or its activities affect, interstate or foreign commerce.
- At the motion-to-dismiss stage, a civil RICO complaint adequately pleads standing when it alleges racketeering predicate conduct (such as extortion) and resulting injury to the plaintiff’s business or property.

## Conclusion

The Court held that civil RICO claims are not limited to profit-driven enterprises: a noneconomic, ideologically motivated association can be a RICO enterprise if the statutory elements are otherwise satisfied, and allegations of extortion and business/property injury suffice to plead standing at the dismissal stage.


Nat'l Org. for Women, Inc. v. Scheidler, 510 U.S. 249 (1994)