In United States v. Mongols Nation, --- F.4th ---, No. 19-50176 (9th Cir. 2023), the Court affirmed the Mongol Nation's RICO conviction and affirmed the district court’s order denying forfeiture of certain collective membership marks.
"Mongol Nation appealed its conviction and sentence, and the Government cross-appealed the order denying forfeiture of the marks. The parties’ cross-appeals present two issues. First, did the district court lack jurisdiction because Mongol Nation does not qualify as a “person” as defined by RICO; and second, did the district court err in denying forfeiture of the Mongol Nation marks?"
"We affirm. There was no defect in the district court’s jurisdiction stemming from RICO’s definition of 'person,' and we agree with the district court that denial of forfeiture was appropriate under these circumstances."