Medallion TV Enterprises, Inc. v. SelecTV of California, Inc.

Summary

The United States District Court for the Central District of California granted defendants' motion for summary judgment in a civil RICO and state-law action arising from a failed joint venture to televise the Ali-Berbick heavyweight prizefight. The court held that the alleged predicate acts, even if proved, constituted a single criminal episode and therefore did not establish the continuity required for a RICO pattern. The court also concluded that the civil RICO conspiracy claim required overt acts causing injury under 18 U.S.C. § 1964(c).

Holdings

1. The alleged predicate acts, even if proved, did not establish a pattern of racketeering activity because they arose from one criminal episode involving a single fraudulent scheme.
2. A private civil RICO conspiracy claim requires at least one or more overt acts causing injury to the plaintiff's business or property, and the alleged conspiracy must concern a pattern of racketeering activity; plaintiffs presented no evidence creating a genuine issue on those requirements.
3. After granting summary judgment on all federal RICO claims, the court declined to exercise pendent jurisdiction over the state-law claims and dismissed them without prejudice.

Questions Presented

1. Whether the alleged telephone calls and transfer of letters of credit constituted a pattern of racketeering activity under 18 U.S.C. §§ 1962(b) and (c).
2. Whether plaintiffs could maintain a private civil RICO conspiracy claim under 18 U.S.C. § 1962(d) without proving a pattern of racketeering activity and overt acts causing injury.
3. Whether the court retained pendent jurisdiction over the state-law claims after granting summary judgment on the federal RICO claims.

Disposition

other