The article discusses the role of Racketeer Influenced and Corrupt Organizations Act (RICO) during criminal proceedings which have both criminal and civil liability for violations of prohibited activities. The U.S. Supreme Court case H.J. Inc. v. Northwestern Bell Telephone Co. in which the Court rejected the Eighth Circuit\u27s requirement of multiple schemes. The U.S. Court of Appeal for the Eighth Circuit held that a single scheme is not sufficient to satisfy the continuity element
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