Targeting banks mostly in the New York City area, each member of the crew had assigned tasks; Boyle's job was to steal the getaway car.

[6] Boyle's attorneys argued that to be considered an enterprise, a group needed some form of clear organization or hierarchy, which they claimed the Night Drop Crew lacked.

The term meant, Stevens believed, "to refer only to business-like entities that have an existence apart from the predicate acts committed by their employees or associates."

The Court's interpretation, he wrote, "will allow juries to infer the existence of an enterprise in every case involving a pattern of racketeering activity undertaken by two or more associates.

"[10] A year after the Supreme Court rejected his appeals, Boyle was convicted in an unrelated charge of murder, stemming from a 1998 mob killing in Staten Island.