North Bridge Associates, Inc. v. Boldt

Real estate fraud plaintiffs failed to establish "continuity" in support of RICO claim where alleged racketeering activity was defendant's mailing of two letters, four months apart, demanding purportedly excessive legal fees related to foreclosure.

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The full case caption appears at the end of this opinion.

COFFIN, Senior Circuit Judge. Appellants claim that they twice were victims of real estate frauds perpetrated by appellee Benjamin Boldt and others. [FOOTNOTE 1] They brought suit alleging a variety of state law claims and a violation of the Racketeer Influenced and Corrupt Organizations Act (“RICO”), 18 U.S.C. � 1962(c). The district court concluded, inter alia, that appellants could not show the pattern of racketeering activity required to support RICO liability and therefore dismissed the complaint. [FOOTNOTE 2] Appellants argue that their factual allegations were sufficient to support recovery and that, in any event, the court should not have dismissed the complaint without providing them a hearing and an opportunity to amend or conduct discovery. We affirm.

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North Bridge Associates, Inc. v. Boldt

Real estate fraud plaintiffs failed to establish "continuity" in support of RICO claim where alleged racketeering activity was defendant's mailing of two letters, four months apart, demanding purportedly excessive legal fees related to foreclosure.

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