## Facts

- The United States sued the International Brotherhood of Teamsters, Chauffeurs, Warehousemen and Helpers of America, AFL-CIO (IBT), alleging violations of the Racketeer Influenced and Corrupt Organizations Act (RICO) arising from the union’s relationship with La Cosa Nostra.
- The government alleged that organized-crime influence corrupted the union and involved racketeering-related misconduct connected to union affairs.
- The parties settled rather than proceed to trial.
- As part of the settlement, the IBT agreed to refrain from engaging in racketeering activity and to refrain from knowingly associating with members of La Cosa Nostra.
- To implement and police these commitments, the district court entered a consent decree that established ongoing oversight mechanisms within the union.
- The decree provided for the appointment of three officers to oversee specified union operations.
- The decree also created an independent review board designed to investigate future allegations of illegal union activity tied to racketeering or La Cosa Nostra.

## Issues

1. Whether the district court could enter and enforce a civil RICO consent decree imposing prospective obligations on the union to refrain from racketeering and knowing association with La Cosa Nostra.
2. Whether the consent decree could install court-supervised oversight—through appointed officers and an independent review board—to investigate and address future racketeering-related misconduct within the union.

## Decision

- The case resolved through a negotiated settlement, and the district court entered a consent decree reflecting the parties’ agreement.
- The consent decree bound the IBT to prospective conduct restrictions, including prohibitions on racketeering activity and knowing association with La Cosa Nostra members.
- The court’s decree established an oversight structure, including three appointed officers to oversee defined union functions.
- The decree created an independent review board with authority to investigate future allegations of illegal union activity connected to racketeering or La Cosa Nostra.

## Legal Principles

- A consent decree is a court order that memorializes a settlement and is enforceable through the court’s equitable powers.
- In civil RICO matters, prospective injunctive relief may be used to prevent future racketeering-related misconduct and to separate an organization from criminal influence.
- A court may approve settlement terms that include compliance monitoring and investigatory structures when those terms are directed at preventing future violations addressed by the complaint.
- When a consent decree establishes ongoing oversight mechanisms, the decree’s terms govern the parties’ obligations and the operation of the court-approved monitoring framework.

## Conclusion

United States v. International Brotherhood of Teamsters concerns a civil RICO enforcement action that ended in a court-entered consent decree requiring the IBT to refrain from racketeering and from knowingly associating with La Cosa Nostra members, while also setting up court-supervised oversight—through appointed officers and an independent review board—to investigate and respond to future racketeering-related allegations within the union.


United States v. International Brotherhood of Teamsters, Chauffeurs, Warehousemen and Helpers of America, AFL-CIO, No. 988 Civ. 4486 (1989)