Salinas v. U.S

In Salinas v. U.S., 522 U.S. 52, 59, 139 L. Ed. 2d 352, 118 S. Ct. 469 (1997), the Supreme Court did not directly address the Reves' test but stated that a person need not personally commit two predicate acts to be liable under section 1962(d). See 522 U.S. at 64. "A conspiracy may exist even if a conspirator does not agree to commit or facilitate each and every part of the substantive offense." Id. at 63. Conspirators are liable for the acts of their co-conspirators who agree to pursue the same criminal objective. Salinas supports the rule adopted by the majority of circuit courts that a person need not participate in the enterprise's operation or management to be liable for a RICO conspiracy.