Brief of Amici Curiae of Ohio Right to Life Society, Inc., Cleveland Lawyers for Life, Inc., Physicians for Life, Inc. in support of Respondents, National Organization for Women v. Scheidler, 114 S. Ct. 798 (1993)

(In this action, petitioner health care clinics alleged, among other things, that respondents, a coalition of antiabortion groups called the Pro-Life Action Network (PLAN) and others, were members of a nationwide conspiracy to shut down abortion clinics through a pattern of racketeering activity -- including extortion under the Hobbs Act -- in violation of the Racketeer Influenced and Corrupt Organizations Act (RICO) chapter of the Organized Crime Control Act of 1970, 18 U.S.C. §§ 1961-1968.)

Amici contend that the ordinary canons of statutory interpretation support the Seventh Circuit's conclusion below that the Racketeer Influenced and Corrupt Organizations ("RICO") chapter of the Organized Crime Control Act of 1970, Pub.L. 91-452, Title IX, 84 Stat. 941 (1971), requires an economic element in the terms "enterprise" and in the predicate acts subject to its provisions. NOW v. Scheidler, 968 F.2d 612 , 626-29 (7th Cir. 1992). The issue, however, only arises because of the evident ambiguity in the concept of "enterprise" within 18 U.S.C. § 1962(c) (1989) , and in the type of motivation required for a predicate act. It is that ambiguity and its clarification which Amici address in this brief.