Richardson v. United States case brief

Richardson v. United States

1. 1. Defendant Richardson was charged with violating CCE as the head of the Undertaker Vice Lords, who (among other things) distributed drugs in Chicago.
   2. Defendant challenged his conviction based upon the “series of violations” requirement.
   3. In reviewing the case, the Supreme Court said that, by the terms of § 848, the trial jury’s CCE conviction was only proper the jury unanimously agreed on what each of the “violations” were in the “series,” and they must agree on at least 3 violations in order to make up a series. (In other words, the court’s review focused upon the word “violations” instead of the word “series.”) Judgment vacated, case remanded to be decided on those terms.
   4. Spirited dissent said that focusing on 3 individual violations within an enterprise that continuously committed thousands missed the purpose of the statute.