The court of appeals affirmed a district court judgment. The court held that for purposes of a prison gang member’s substantive RICO conviction, the Aryan Brotherhood prison gang remained a single criminal enterprise before and after a 1993 restructuring where the group retained its overarching framework for achieving criminal objectives and had members who worked as a continuing unit to achieve a common purpose.
Tyler Bingham was one of three members of the Aryan Brotherhood’s Commission, which was formed in 1993 as part of a plan to transform the Aryan Brotherhood (AB) prison gang into an effective criminal organization. The Commission replaced a less formal three-person Council. As restructured, the Commission oversaw the AB, while the Council implemented the Commission’s programs and individual gang members carried out logistical tasks. Edger Hevle was a member of the first Council.
