Civil RICO · 18 U.S.C. §§ 1961–1968
The Civil RICO theory as pleaded — predicate acts, an alleged enterprise, an alleged pattern, and a § 1964(c) business-or-property injury — raised in the operative First Amended Complaint and dismissed with prejudice below on res judicata grounds; the dismissal is now on appeal at the First Circuit (No. 26-1346). Nothing here has been adjudicated in the litigant’s favor; each entry states what the filings assert, pending the appeal.
"Plaintiff-Appellant … asserted claims under … Civil RICO (18 U.S.C. § 1962), arising from the sustained and systemic deprivation of his constitutional rights by Massachusetts state officials and others acting in concert with the State." — Appellant’s Brief, No. 26-1346 (Jurisdictional Statement)
The operative First Amended Complaint pleads a "sustained and systemic Civil RICO-like (18 U.S.C. § 1962) organized conspiracy" as Count IV, incorporating the prior counts. It frames the defendants as having allegedly violated civil rights "with long-term, organized, Civil-RICO-like patterns of racketeering through repeated cycles of unlawful acts." This is the theory the complaint asserts; it is not a finding.
Filed PDF →The complaint identifies the asserted "RICO Predicate Acts" as three recurring categories: mail and wire fraud, obstruction of justice, and retaliation. It pleads these as "repeated cycles of organized acts — reflecting a now 14+ years-long racketeering pattern." The page records the predicate-act allegation as asserted-and-pending; a "racketeering activity" under § 1961(1) is what the complaint must establish, not what any court has found.
Filed PDF →The renewed RICO complaint to the FBI Director — filed concurrently as Exhibit 2 in the underlying District of Massachusetts action (Doc 9-2) — asserts an enterprise of state officials and adjudicatory bodies allegedly acting in concert with private actors, including an out-of-state provider pleaded as the "interstate-commerce"-supplying participant. It asserts a "long-term, endlessly repeated" racketeering pattern. The pattern element — relatedness plus continuity, the standard set by H.J. Inc. — is what such a claim must establish; here it is alleged, pending review.
Filed PDF →The Appellant’s Brief asserts the business-or-property injury underlying the § 1964(c) standing theory: what it characterizes as a 13-year pattern of "fraud on the court," the alleged removal of a 437-item set of requests for admissions from the docket on, by the brief’s count, 16 documented occasions, and over $500,000 in accumulated child-support arrears. These are the brief’s own assertions, contested and unadjudicated; the § 1964(c) injury element has not been found.
Filed PDF →The Appellant’s Brief states that the District Court dismissed the operative complaint with prejudice on March 25, 2026 under 28 U.S.C. § 1915(e)(2)(B)(ii), on res judicata grounds, and denied the subsequent Rule 59(e) / 60(b)(6) motion. The brief asks the First Circuit to reverse. The Civil RICO theory therefore stands dismissed below and pending on appeal — the page presents the theory raised, not relief obtained.
Filed PDF →