The Inapplicability of RICO Law to Levi Sap Nei Thang

Background & Case Summary

The presiding judge in this matter, Judge Hernán D. Vera, serves on the United States District Court for the Central District of California. He was appointed to the federal bench by President Joe Biden and confirmed by the United States Senate in 2023.

Confirmation Vote: His federal confirmation was split strictly along party lines, with a 51-48 vote in the Senate where all 48 “yea” votes came from Democrats and all 48 “nay” votes came from Republicans

In February 2025, Judge Vera presided over a civil federal case in which a group of Burmese refugee plaintiffs brought claims of fraud and racketeering against Levi Sap Nei Thang. The plaintiffs alleged that Ms. Thang sold them U.S. federal oil and gas leases at highly inflated prices, representing that she could help them generate profits through oil drilling ventures. According to the plaintiffs, these representations induced them to invest substantial sums of money that ultimately resulted in financial losses.

Original Judgment, RICO Finding, and Damages

On June 12, 2025, Judge Vera entered judgment against Ms. Thang, awarding the plaintiffs more than $3.2 million in damages. The judgment included:

  • Economic damages, representing the plaintiffs’ claimed financial losses;
  • Punitive damages, intended to punish and deter misconduct; and
  • Treble damages, awarded under federal racketeering statutes.

The court ruled that Ms. Thang’s conduct constituted fraud and racketeering under the Racketeer Influenced and Corrupt Organizations Act (RICO), concluding that her actions caused significant economic harm to the plaintiffs. The decision characterized the alleged conduct as part of a broader pattern of deceptive business practices.

At the time, the ruling was viewed as a significant application of civil RICO law to a dispute involving private financial transactions.

Amended Judgment and Reduction of Damages

On September 5, 2025, counsel for Ms. Thang filed a motion challenging the punitive damages portion of the judgment. The motion argued that the punitive damages award was legally improper because the plaintiffs had failed to present the required evidence of Ms. Thang’s financial condition—an essential legal prerequisite for punitive damages under established law.

After reviewing the motion, the court agreed

On October 15, 2025, the federal court issued an amended judgment reducing the total award from approximately $3.2 million to $1.8 million. The reduction resulted from the court’s decision to vacate a large portion of the punitive damages due to insufficient supporting evidence.

Although the judgment was substantially reduced, a significant monetary award remains in place. Counsel for Ms. Thang has indicated that an appeal will be pursued to challenge additional aspects of the case.

Significance of the Case

This case has drawn attention for several reasons:

  • The size of the original damages award
  • The use of RICO statutes in a civil fraud dispute
  • The legal questions surrounding the proper application of punitive and treble damages

Civil RICO cases are relatively rare and are subject to strict legal standards. The case highlights the powerful—but often controversial—nature of RICO remedies when applied outside traditional organized crime contexts.

Understanding RICO and Its Historical Connection to the Mafia

Purpose of the RICO Law

The Racketeer Influenced and Corrupt Organizations Act (RICO), codified at 18 U.S.C. §§ 1961–1962, is a federal statute enacted in 1970. It was originally designed to combat organized crime syndicates, particularly the American Mafia.

Before RICO, it was extremely difficult for prosecutors to hold high-level criminal leaders accountable. Mafia bosses often insulated themselves from direct involvement in crimes, using layers of associates to carry out illegal activity. RICO was created to solve this problem by allowing the government to prosecute entire criminal enterprises rather than just individual acts.

RICO and the Mafia – The Original Target

RICO was developed largely in response to the growing power of organized crime families such as:

  • The Gambino
  • Genovese
  • Lucchese
  • Colombo
  • Bonanno crime families

Under RICO, prosecutors could charge Mafia leaders for:

  • Running illegal gambling operations
  • Extortion and loan sharking
  • Bribery and corruption
  • Drug trafficking
  • Money laundering

Even if a Mafia boss never personally committed a crime, RICO allowed the government to hold them responsible for directing or benefiting from a “pattern of racketeering activity.”

RICO Today: Broader Than the Mafia

Although RICO was created with the Mafia in mind, it is not limited to organized crime syndicates. Over time, the statute has been expanded to include:

  • Corporate fraud schemes
  • Street gangs
  • Political corruption
  • White-collar crime rings
  • Civil lawsuits between private parties

However, despite its broad scope, RICO remains a complex and demanding statute that requires strict proof.

What RICO Legally Requires

To establish a RICO violation, a plaintiff must prove all of the following elements:

  1. The existence of an “enterprise”
  2. A pattern of racketeering activity
  3. At least two qualifying criminal acts
  4. Intent to defraud or engage in unlawful conduct
  5. A direct connection between the alleged crimes and the claimed losses

Failure to prove any one of these elements defeats a RICO claim.

Key Legal Definitions

  • “Racketeering activity” refers to specific serious crimes listed in the statute, including:
    • Mail fraud
    • Wire fraud
    • Bribery
    • Extortion
    • Money laundering
    • Obstruction of justice
  • Ordinary business disputes, contract disagreements, or poor investments do not qualify as racketeering.
  • A “pattern of racketeering activity” requires repeated, intentional criminal acts. A single disagreement or isolated transaction is not enough.

Application to the Case of Levi Sap Nei Thang

The RICO claims against Ms. Thang were based entirely on allegations of fraud. However, according to the defense, the evidence presented at trial failed to establish the essential legal elements required under the statute.

The defense maintains that the trial record demonstrated:

  • No intentional misrepresentations were proven
  • No intent to deceive was established
  • No criminal “enterprise” existed
  • The plaintiffs’ losses resulted from their own failure to pay required government fees, not from fraud

Without proof of these required elements, the RICO statute cannot lawfully be applied.

Improper Award of Damages

The District Court originally awarded:

  • Compensatory damages
  • Treble damages under RICO
  • Attorneys’ fees

Because the underlying findings of fraud and racketeering are disputed and allegedly unsupported by sufficient evidence, the defense argues that these awards are legally invalid and must be reversed on appeal.

Conclusion

RICO is a powerful federal law created to combat organized criminal enterprises such as the Mafia. It is intended for intentional, repeated criminal conduct—not for ordinary commercial transactions or business disputes.

The sale of government-issued oil and gas leases, with full disclosure and absent proof of deception or criminal intent, does not meet the legal definition of racketeering activity. For these reasons, the defense contends that the RICO judgment and related damages awards should ultimately be overturned.

Judicial Information

The case was presided over by Judge Hernán D. Vera of the United States District Court for the Central District of California, who was nominated to the federal bench by President Joe Biden.

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