Giles v. Garwood

How later courts describe this case

• holding that a RICO enterprise may consist of individuals associated in fact with corporations
• requiring separate jury instructions, deliberations and closing arguments for forfeiture after guilt phase, but declining to require evidentiary hearings in all cases
• “eighth amendment concerns may arise when a defendant must forfeit his or her entire interest in an otherwise legitimate business, even though only a few minor acts in the course of conducting the business were the predicate acts sufficient for a RICO violation”