Leon Black And The Tossed RICO Case

Leon Black, the billionaire co-founder of Apollo Global Management, filed a civil RICO lawsuit in 2023 against his accuser, former Russian model Guzel Ganieva, and her attorneys, alleging they engaged in an extortion and fraud scheme by fabricating sexual assault claims to extract money from him. Black’s suit claimed that Ganieva and those advising her knowingly made false allegations, manipulated evidence, and used media pressure as leverage, framing the dispute not as a question of abuse but as a criminal enterprise under the Racketeer Influenced and Corrupt Organizations Act. The filing was aggressive by design, attempting to flip the narrative and place Black in the role of victim while casting his accuser as part of an organized shakedown.

The federal court ultimately rejected that framing and dismissed the RICO case, finding that Black failed to plausibly allege the existence of a racketeering enterprise or a pattern of racketeering activity as required under the statute. The judge concluded that what Black described amounted to a private civil dispute—however bitter and high-stakes—not a criminal conspiracy governed by RICO law. The dismissal did not resolve the underlying abuse allegations or validate either side’s broader claims; it simply made clear that RICO was not the proper legal vehicle for Black’s counteroffensive. The ruling underscored how difficult it is to stretch racketeering law to cover personal misconduct disputes, even when vast wealth, reputational damage, and high-profile accusations are involved.


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