State v. Beverly
Annotate this CaseIn 2011, Defendant was convicted of several felonies, including receiving stolen property, burglary, and engaging in a pattern of corrupt activity. The convictions arose out of the practice of Defendant and another individual of stealing or receiving stolen vehicles and using those vehicles to commit several burglaries. The court of appeals reversed the conviction for engaging in a pattern of corrupt activity, concluding that there was not evidence that Defendant was “involved in any type of ongoing organization, functioning as a continuing unit, with a structure separate and apart from the pattern of corrupt activity.” The Supreme Court reversed, holding (1) the existence of an enterprise, sufficient to sustain a conviction for engaging in a pattern of corrupt activity, can be established without proving that the enterprise is a structure separate and distinct from a pattern of corrupt activity; and (2) the evidence was sufficient to sustain Defendant’s conviction for engaging in a pattern of corrupt activity in this case.
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