In the past, this column has predominantly involved attorney civil liability mostly focusing on legal malpractice. This edition is intended to outline the elements of attorney-based RICO misconduct; while in a criminal context, civil RICO generally does not differ much.

It is impossible to ignore the headlines surrounding former President Donald Trump’s attorneys’ criminal liabilities. That said, we need not look further than our own backyard: United States v. Bergrin, 650 F.3d 257 (C.A. 3 2011).