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Anza v. Ideal Steel Supply Corp.

United States Supreme Court
547 U.S. 451 (2006)

Written by Sharon Feldman, JD

Facts

Ideal Steel Supply Corp. (Ideal) (plaintiff) and National Steel Supply, Inc., owned by Joseph and Vincent Anza (collectively National) (defendants) were competitor businesses that sold steel-mill products from stores in the same geographic areas. Ideal sued National, alleging that National was engaged in a pattern of racketeering activity to gain sales and market share by failing to charge New York sales tax to cash-paying customers. The alleged racketeering activities were mail and wire fraud committed when National mailed and electronically filed fraudulent state tax returns. The district court dismissed Ideal’s complaint. The Second Circuit vacated the judgment, holding that the complaint adequately alleged a pattern of racketeering activity that gave National a competitive advantage. The Supreme Court granted certiorari.

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