Retroactive Application of the Pennsylvania Corrupt Organizations Act

In Commonwealth v. Shaffer, 557 Pa. 453, 734 A.2d 840 (1999), the Supreme Court had previously held that the act known as the Pennsylvania Corrupt Organizations Act, 18 Pa. C.S. 911, as amended, applied only to legitimate enterprises, and the legislature amended the act to make it apply to illegitimate enterprises as well. The Supreme Court held that the legislature failed to indicate clearly that the amendment should be applied retroactively, and it stated further that although legislative history indicated that certain legislators desired to overrule the court's earlier decision, the legislature lacked the authority to do so.