Background
William Boylston was a member of the Clarksville, Tennessee chapter of the Mongols Motorcycle Club, which prosecutors alleged operated as a racketeering enterprise involved in drug trafficking and violence. Boylston joined the chapter in 2016 and became a fully patched member.
Prosecutors presented evidence that Boylston and fellow Mongol Jason Meyerholz later abducted former member Stephen Cole over missing motorcycles and an unpaid debt. Cole was restrained and tortured in a shed before he died, after which his body was placed in Meyerholz’s truck for disposal. A jury convicted Boylston of RICO conspiracy and offenses including assault, kidnapping resulting in death, kidnapping and murder in aid of racketeering, and a related firearm crime. He received life imprisonment plus a consecutive 84-month term.
The Court’s Holding
The Sixth Circuit affirmed Boylston’s convictions and sentence as part of a consolidated appeal by seven defendants. It held that the evidence sufficiently established the Clarksville Mongols as an association-in-fact enterprise with a common purpose, relationships among its members, and sufficient longevity. The enterprise sought to sell drugs, protect its territory through violence, and establish itself as Clarksville’s dominant outlaw motorcycle club.
The court rejected Boylston’s contention that he was not part of the enterprise, noting that his trial counsel had expressly admitted his membership and thereby waived a contrary argument. His asserted lack of involvement in drug sales did not undermine the RICO-conspiracy conviction because drug trafficking was only one part of the enterprise’s purpose, Boylston participated in its violent activity, and a conspirator need not participate in every act. His later entry into the organization also provided no defense because a person who knowingly joins an existing conspiracy takes it as he finds it.
Key Takeaways
- An informal organization may qualify as a RICO enterprise when its members share a purpose, maintain relationships, and operate together long enough to pursue that purpose.
- A defendant need not participate in every category of racketeering activity to be convicted of joining a RICO conspiracy.
- A late-joining conspirator may be held responsible for a conspiracy already underway, and a concession by trial counsel can waive a contrary position on appeal.
Why It Matters
The decision illustrates the breadth of RICO conspiracy liability in prosecutions of organized criminal groups. Formal recognition by a national organization is unnecessary when the evidence shows that a local group already functioned as an enterprise, and individual members cannot avoid liability merely because they joined later or participated in only one aspect of the enterprise’s criminal program.