145 S.Ct. 931
U.S.2025Background
- Plaintiff Douglas Horn, a commercial truck driver, bought Dixie X (marketed as a THC‑free CBD tincture) and later tested positive for THC; his employer fired him after he refused a substance‑abuse program.
- Horn sued Medical Marijuana, Inc. under civil RICO, alleging the company’s marketing and distribution involved mail/wire fraud predicate acts that caused his job loss and other economic harms.
- The District Court granted summary judgment for defendants, accepting a theory that Horn’s lost employment derived from an antecedent personal injury (ingestion of THC) and that §1964(c) bars recovery for harms that flow from personal injuries.
- The Second Circuit reversed, holding that §1964(c) does not categorically bar recovery for business or property harms that derive from personal injuries and (without deciding it) accepted that Horn was "injured in his business" when he lost his job.
- The Supreme Court affirmed the Second Circuit: (1) it held the so‑called antecedent‑personal‑injury bar is not implied by §1964(c); (2) it construed "injured" in §1964(c) in ordinary terms (harmed/damaged), not strictly as a tort‑law term meaning invasion of a legal right; and (3) it left open whether Horn actually suffered a personal injury, whether "business" includes employment, and what counts as "property" under §1964(c).
Issues
| Issue | Plaintiff's Argument | Defendant's Argument | Held |
|---|---|---|---|
| Whether civil RICO bars recovery for business or property harms that derive from a personal injury (the "antecedent‑personal‑injury bar") | Horn: §1964(c) permits recovery for business/property harm even if it results from a personal injury | Medical Marijuana: RICO excludes personal‑injury suits and therefore also bars business/property claims that are derivative of personal injury | Held: No categorical antecedent‑personal‑injury bar; plaintiff may seek damages for business/property harm even if loss derived from a personal injury |
| What "injured" means in §1964(c): ordinary harm vs. tort‑law term of art (invasion of legal right) | Horn: "Injured" should be read in its ordinary sense—harmed or damaged—so business/property losses count | Medical Marijuana: "Injured" is a tort term meaning invasion of a legally protected business/property right; personal injuries cannot be recast as RICO injuries | Held: Court adopts ordinary meaning—"injured" means harmed/damaged—rejecting a rule that would import the tort‑law legal‑right requirement wholesale into §1964(c) |
| Whether "business" includes employment and whether Horn pleaded a qualifying business or property injury | Horn: loss of employment is an injury "in his business" | Medical Marijuana: disputed that Horn pleaded a business/property injury distinct from a personal injury | Held: Court did not decide those questions (left for remand/later proceedings) |
Key Cases Cited
- Sedima, S. P. R. L. v. Imrex Co., 473 U.S. 479 (1985) (compensable RICO injury is the harm caused by predicate acts)
- Holmes v. Securities Investor Protection Corp., 503 U.S. 258 (1992) (RICO requires a direct relation between injury and injurious conduct)
- Hemi Group, LLC v. City of New York, 559 U.S. 1 (2010) (RICO proximate‑cause/directness requirement limits recovery)
- Anza v. Ideal Steel Supply Corp., 547 U.S. 451 (2006) (directness and causal limits on RICO recovery)
- Bridge v. Phoenix Bond & Indemnity Co., 553 U.S. 639 (2008) (RICO recovery requires legally cognizable injury under common‑law principles when appropriate)
- RJR Nabisco, Inc. v. European Community, 579 U.S. 325 (2016) (declining to import Clayton Act injury rules into RICO; Congress’ choices matter)
- Yegiazaryan v. Smagin, 599 U.S. 533 (2023) (contextual, fact‑intensive inquiry over common‑law situs rules for RICO injuries)
- Keogh v. Chicago & Northwestern R. Co., 260 U.S. 156 (1922) (antitrust precedent treating "injury" as implying violation of a legal right)
- Reiter v. Sonotone Corp., 442 U.S. 330 (1979) (antitrust exclusion of personal‑injury suits and treatment of legal‑injury requirement)
- Chattanooga Foundry & Pipe Works v. Atlanta, 203 U.S. 390 (1906) (payments induced by fraud can constitute injury to property)