Mohawk Industries, Inc. v. Williams
Williams, and several other employees of Mohawk, sued Mohawk for violating the Racketeer Influenced and Corrupt Organizations Act (RICO) by hiring illegal aliens to reduce labor costs. To establish a civil RICO claim, a plaintiff must show that the defendant participated in the conduct of an enterprise through a pattern of racketeering (i.e. illegal) activity. The plaintiffs alleged that Mohawk conspired with third-party recruiters to violate federal immigration laws, destroy documentation, and harbor illegal workers. The recruiters were paid for each worker they brought to Mohawk, and some of the recruiters worked closely with Mohawk by offering illegal employees that could be brought to any of Mohawk's facilities on short notice. The district court held that Mohawk's collaboration with the third-party recruiters sufficiently established an "enterprise." The Court of Appeals for the Eleventh Circuit affirmed, holding that RICO only requires a "loose or informal" association of entities to establish an "enterprise."
Question Presented:
Whether a defendant corporation and its agents can constitute an "enterprise" under the Racketeer Influenced and Corrupt Organizations Act, 18 U.S.C. ยงยง 1961-1968 ("RICO"), in light of the settled
rule that a RICO defendant must "conduct" or "participate in" the affairs of some larger enterprise and not just its own affairs.
