a pattern. While declining to establish a specific test to be applied by lower courts, Justice White pointed to language in the legislative history of the act suggesting that a pattern of. activity must exhibit “continuity plus relationship.” Id. at 496 n. 14, 105 S.Ct. at 3285 n. 14. By focusing on these two concepts, lower courts could develop their own standards’ for determining the existence of a pattern of racketeering activity. Id. Although Sedima attempted to provide a theoretical foundation for the pattern analysis, as a practical matter, the concept remained as vague and amorphous as it had been prior to Sedima. Evidence of this uncertainty can be seen in the wide range of approaches developed by Circuit Courts. See Superior Oil Co. v. Fulmer, 785 F.2d 252 (8th Cir.1986) (<HOLDING>); R.A.G.S. Couture, Inc. v. Hyatt, 774 F.2d
holding that to prevail under civil rico plaintiff must prove that defendants participated in the conduct of an enterprise through a pattern of racketeering activity recognizing that by accepting bribes in exchange for allowing violations of a collective bargaining agreement the defendant was conducting the rico enterprise local union through racketeering activity even though the union was harmed by the racketeering activity holding that plaintiffs allegation that defendant engaged in multiple instances of mail and wire fraud did not allege pattern of racketeering activity with sufficient particularity holding that plaintiff stated pattern of racketeering activity where defendants allegedly committed various predicates with common design of defrauding plaintiffs of money and obtaining control of coal mine holding that a pattern of racketeering activity required multiple illegal schemes