Horn v. Medical Marijuana, Inc., 80 F.4th 130

Horn, a 29-year commercial truck driver subject to DOT random drug testing, purchased Dixie X CBD drops advertised as 0% THC.
After using the product, Horn tested positive for THC, lost his job and attendant wages, insurance, and pension benefits; independent testing later confirmed the product contained THC.
Horn sued Dixie and related entities asserting civil RICO (mail/wire fraud predicates) and state-law claims; most state claims narrowed, and the RICO claim survived initial dismissal.
The district court granted summary judgment for defendants on the RICO claim, adopting an "antecedent-personal-injury" rule that bars RICO recovery for pecuniary losses that flow from a prior personal injury.
The Second Circuit vacated and remanded, holding §1964(c) permits suit for injuries to "business or property" even when those economic harms flowed from an antecedent personal injury; it rejected the antecedent-personal-injury bar and applied proximate-cause analysis.

Issue	Plaintiff's Argument	Defendant's Argument	Held
Whether §1964(c) bars recovery for business/property losses that flow from an antecedent personal injury	Horn: §1964(c) authorizes recovery for business or property injuries even if a personal injury preceded them	Appellees: Lost earnings are derivative of a personal injury (unconsented bodily invasion) and thus not recoverable under RICO	Rejected the antecedent-personal-injury bar; §1964(c) allows business/property injuries to be redressed when proximate to racketeering conduct
Whether loss of employment qualifies as an "injury in his business" under §1964(c)	Horn: Employment is "business"; termination and lost wages/benefits are business injuries	Appellees: Losses are tied to a personal injury and thus nonrecoverable	Employment and attendant lost earnings fall within the ordinary meaning of "business," so Horn suffered a business injury
Whether judicial policy concerns (floodgates) justify imposing an extra-textual limitation on RICO standing	Horn: Sedima forbids courts from adding standing limits beyond the statute; proximate-cause and other limits suffice	Appellees: A restrictive rule prevents RICO being used to recast personal-injury claims as property harms	Court: Policy concerns cannot override clear statutory text; proximate-cause and existing statutory limits control misuse

Holmes v. Sec. Investor Prot. Corp., 503 U.S. 258 (establishes proximate-cause test for RICO causation)
Sedima, S.P.R.L. v. Imrex Co., 473 U.S. 479 (rejects judicially-imposed "racketeering injury" requirement; admonishes courts not to add standing limits)
Reiter v. Sonotone Corp., 442 U.S. 330 (interpreting "business or property" language in Clayton Act analogue)
Diaz v. Gates, 420 F.3d 897 (9th Cir.) (rejects antecedent-personal-injury bar; treats employment as business injury)
Jackson v. Sedgwick Claims Mgmt. Servs., 731 F.3d 556 (6th Cir. en banc) (advances antecedent-personal-injury bar adopted by some circuits)
RJR Nabisco, Inc. v. European Community, 579 U.S. 325 (recognizes that §1964(c) implicitly excludes personal-injury recovery)
Agency Holding Corp. v. Malley-Duff & Assocs., Inc., 483 U.S. 143 (characterizes RICO as designed to remedy economic injury)
Bankers Trust Co. v. Rhoades, 741 F.2d 511 (2d Cir.) (distinguishes personal injury from business/property damage under §1964(c))