In the case of Edmund Boyle v. United States, 2008, the Supreme Court ruled in favor of the government's broader interpretation of what constitutes an "enterprise" under RICO (Racketeer Influenced and Corrupt Organizations Act). The defendant, Edmund Boyle was a member of a criminal group involved in several bank robberies. He argued that his group did not qualify as an enterprise because it lacked structure separate from the pattern of racketeering activity for which they were prosecuted. However, Justice Samuel Alito writing for a unanimous court disagreed with this argument stating that an association-in-fact enterprise must have a “structure” but does not require hierarchy or role differentiation among members nor existence beyond duration necessary to commit offenses; rather it requires only relationships among associates and sufficient longevity to permit these associates to pursue enterprises' purpose. Therefore, even loosely structured groups can be considered enterprises under RICO if they meet these criteria.

In the dissenting opinion for Edmund Boyle v. United States, Justice Antonin Scalia argued that the Court's interpretation of "enterprise" in RICO (Racketeer Influenced and Corrupt Organizations Act) was too broad. He contended that an enterprise must have a structure separate from the pattern of racketeering activity it engages in to qualify under RICO. According to him, this requirement is not met by simply showing that individuals associated together for criminal purposes; there needs to be evidence of an organizational structure beyond just committing crimes together. Furthermore, he criticized the majority’s reliance on legislative history rather than statutory text as a basis for their decision-making process.