General Motors, LLC v. FCA US, LLC, 44 F.4th 548

Background

From 2009–2017 FCA executives and certain UAW leaders engaged in a bribery scheme funneled largely through the UAW-FCA National Training Center; DOJ convictions and guilty pleas followed and FCA pleaded guilty and paid a fine.
GM alleges FCA bought favorable labor concessions and had the UAW withhold comparable benefits from GM (WCM adoption, expanded Tier Two/temporary hiring, grievance handling, cheaper prescription benefits), producing a labor-cost advantage.
In 2015 the UAW selected FCA as the pattern-bargaining target; FCA and UAW negotiated contracts GM says were structured to impose higher costs on GM, which GM then had to accept as a pattern.
GM sued FCA, Fiat, and individual executives under RICO (18 U.S.C. § 1962(b),(c),(d)), relying in part on 29 U.S.C. § 186 as predicate acts; district court dismissed for failure to plead proximate cause and declined supplemental state-law claims; GM moved to alter judgment based on new offshore-account evidence and was denied.
On appeal the Sixth Circuit considered (1) whether Garmon preemption barred federal court adjudication of RICO claims predicated on § 186, and (2) whether GM plausibly alleged both factual and proximate causation under RICO; the court affirmed dismissal.

Issues

Issue	Plaintiff's Argument	Defendant's Argument	Held
Whether Garmon preemption bars federal RICO claims predicated on LMRA § 186	GM: RICO predicates include § 186, so district court can decide labor-law predicates	FCA: NLRA/NLRB has primary jurisdiction; Garmon preemption applies	Court: Congress carved out § 186 as a RICO predicate; Garmon does not bar federal adjudication of RICO claims grounded in § 186
Whether FCA's bribery that produced a marketplace labor-cost advantage proximately caused GM's economic injuries	GM: FCA's corrupt advantages led directly to higher GM costs and lost opportunities	FCA: Any market harm is indirect, caused by competitive pricing and other market factors	Court: Allegations of a competitive advantage are too indirect under Holmes/Anza/Hemi; proximate cause lacking
Whether FCA-directed withholding of similar benefits from GM satisfies but-for and proximate causation	GM: FCA bribed UAW to deny GM benefits, causing higher GM costs	FCA: GM never alleges it was entitled to those benefits absent bribery; no but-for causation	Court: GM failed to plead but-for causation—no plausible allegation it would have received those benefits absent the bribery
Whether 2015 pattern-bargaining injuries (selection of FCA as lead) satisfy RICO directness	GM: FCA bought the lead role and structured CBAs to damage GM, plausibly intending a takeover	FCA: The chain from bribery to GM injury ran through independent actors and events, making causation attenuated	Court: Even accepting GM's alternate theory as plausible, the causal chain is too attenuated and passes through independent actors; proximate cause fails

Key Cases Cited

San Diego Bldg. Trades Council v. Garmon, 359 U.S. 236 (1959) (NLRA/NLRB primary jurisdiction preemption principle)
Holmes v. Securities Investor Prot. Corp., 503 U.S. 258 (1992) (RICO requires both factual and proximate causation; directness requirement)
Anza v. Ideal Steel Supply Corp., 547 U.S. 451 (2006) (competitive-advantage injuries held indirect; proximate cause lacking)
Bridge v. Phoenix Bond & Indem. Co., 553 U.S. 639 (2008) (direct injury requirement can be satisfied where no intermediate, more immediate victim exists)
Hemi Group, LLC v. City of New York, 559 U.S. 1 (2010) (reinforces directness; harms flowing from independent third parties are insufficient)
Bell Atl. Corp. v. Twombly, 550 U.S. 544 (2007) (plausibility standard for pleading)
Ashcroft v. Iqbal, 556 U.S. 662 (2009) (apply plausibility and accept well-pleaded facts)
Trollinger v. Tyson Foods, Inc., 370 F.3d 602 (6th Cir. 2004) (Garmon and NLRA issue preemption framework)
Butchers' Union, Local No. 498 v. SDC Inv., Inc., 631 F. Supp. 1001 (E.D. Cal. 1986) (treats § 186 as a RICO predicate permitting district-court adjudication)
Brennan v. Chestnut, 973 F.2d 644 (8th Cir. 1992) (supports conclusion that § 186 predicates are not Garmon-preempted)