Reich v. Betancourt Lopez, No. 16-510 (2d Cir. 2017)Annotate this Case
Plaintiff challenged the dismissal of his Racketeer Influenced and Corrupt Organizations Act (RICO) and state law claims against the principals of a Venezuelan energy company. The Second Circuit affirmed the dismissal of the RICO claims because plaintiff failed to allege that defendants engaged in a pattern of racketeering activity. Plaintiff's first theory failed because the predicate acts posed no continuing threat of racketeering. Plaintiff's second theory failed because the predicate acts he chose were insufficiently related to each other. The court also affirmed the dismissal of the state law claims because plaintiff failed to establish personal jurisdiction over either defendant.