In Section I, this Comment examines the nature of the violence erupting out of protest activity at abortion clinics. Section II outlines the treatment of different types of federal lawsuits brought by clinics and pro-choice groups against both antiabortion groups and the leaders that spearhead the violent protest campaigns. Section III explores the use of RICO against such groups and individuals, and the imposition of an economic motivation requirement. Section IV discusses both the Seventh Circuit's and the Supreme Court's decisions in NOW v. Scheidler. Section V addresses the concerns surrounding the application of RICO to political protest activities. Section VI looks at Congress' intervention with legislation aimed to protect reproductive health care providers and their patients from violence, blockades, threats, and destruction of property, while ensuring the right to speech and conduct protected by the First Amendment. And Section VII briefly describes the possibilities for application of the two statutes.
Susan L. Ronn, "FACE"-ing RICO: A Remedy for Antiabortion Violence?, 18 SEATTLE U. L. REV. 357 (1995).