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Villanueva-Bazaldua v. TruGreen Limited Partners et al

REPLY BRIEF re MOTION for Leave to File a First Amended Complaint

16 Cited authorities

  1. Holmes v. Securities Investor Protection Corp.

    503 U.S. 258 (1992)   Cited 1,700 times   8 Legal Analyses
    Holding that the Securities Investor Protection Corporation (SIPC) could not recover under RICO for stock-manipulation scheme that bankrupted broker-dealers, triggering a statutory requirement that SIPC meet the broker-dealers' obligations to their customers

  2. Anza v. Ideal Steel Supply Corp.

    547 U.S. 451 (2006)   Cited 875 times   5 Legal Analyses
    Holding that a business could not recover against its competitor for a scheme to defraud the New York State tax authority that allowed the defendant to undercut the plaintiff's prices

  3. Williams v. Mohawk Industries, Inc.

    465 F.3d 1277 (11th Cir. 2006)   Cited 282 times   1 Legal Analyses
    Holding that plaintiffs, employees of a carpet and rug manufacturer, had standing to bring RICO claim based on allegations that the manufacturer conspired to hire undocumented workers to keep wages low

  4. Mendoza v. Zirkle Fruit Co.

    301 F.3d 1163 (9th Cir. 2002)   Cited 203 times   1 Legal Analyses
    Holding that a group of legally documented agricultural workers, who alleged that the defendant fruit grower's hiring of undocumented workers directly harmed them by depressing their wages, stated a civil RICO claim

  5. Tabas v. Tabas

    47 F.3d 1280 (3d Cir. 1995)   Cited 248 times
    Holding scheme lasting over three years is "substantial period of time" for purposes of establishing pattern of racketeering activity

  6. Abraham v. Singh

    480 F.3d 351 (5th Cir. 2007)   Cited 169 times
    Holding that two years was sufficient

  7. Trollinger v. Tyson Foods, Inc.

    370 F.3d 602 (6th Cir. 2004)   Cited 162 times   1 Legal Analyses
    Holding that the NLRA does not "preempt" wage-related RICO claims

  8. Commercial Cleaning Serv. v. Colin Serv. Sys

    271 F.3d 374 (2d Cir. 2001)   Cited 165 times
    Finding RICO injury satisfied because, "[i]f plaintiffs can substantiate their claims, the plaintiffs may well show that they lost contracts directly because of the cost savings defendant realized through its scheme to employ illegal workers"

  9. Trautz v. Weisman

    819 F. Supp. 282 (S.D.N.Y. 1993)   Cited 44 times
    Holding that with passage of the ADA, § 1985 applies to discrimination on the basis of physical disability

  10. United States v. Brown

    583 F.2d 659 (3d Cir. 1978)   Cited 66 times
    In United States v. Brown, 583 F.2d 659 (3d Cir. 1978), a jury convicted the defendant of four substantive offenses and a RICO conspiracy offense whose racketeering acts constituted the four substantive offenses.

  11. Section 1962 - Prohibited activities

    18 U.S.C. § 1962   Cited 16,273 times   61 Legal Analyses
    Specifying prohibited activities

  12. Section 1961 - Definitions

    18 U.S.C. § 1961   Cited 15,225 times   72 Legal Analyses
    Defining what the terms “person” and “enterprise” include