This case involved forfeiture proceedings of a petitioner convicted on three counts of violating RICO. The trial court ordered the mandatory forfeiture of the petitioner's businesses and business assets, in addition to nearly $9 million in racketeering-related earnings. The Court extended the applicability of the Excessive Fines Clause beyond that in previous decisions and held that the Excessive Fines Clause analysis applied. As a result, racketeering defendants may have gained an opportunity to devise ways to keep their most previous commodities: illegal profits. RICO's effectiveness in addressing organized crime depends on how the courts of appeals interpret and apply an Excessive Fines Clause analysis. Therefore, this new area of Eighth Amendment jurisprudence should be defined very carefully. The analysis the courts choose will greatly affect both individual liberties and the government's ability to address organized crime. Footnotes