Reves v. Ernst & Young

In Reves v. Ernst & Young, 507 U.S. 170, 179, 122 L. Ed. 2d 525, 113 S. Ct. 1163 (1993), the Supreme Court adopted the "operation or management test" to define "conduct or participate." To violate section 1962(c), the defendant "must have some part in directing the enterprise's affairs." Id. Liability may extend to any person employed or associated with the enterprise if such a person participates in the enterprise's operation or management. Id. at 184-85.