Wallace v. Midwest Financial & Mortgage Services, Inc., 714 F.3d 414

Wallace purchased a home in 2004 and later refinanced in 2006 via Midwest Financial for a large loan.
Midwest Financial obtained an appraisal from Accupraise; Brock falsely signed appraisals and inflated value to about $500,000.
Soard presented Wallace with a loan offer based on the inflated appraisal, culminating in a $425,000 loan.
MortgageIT approved the refinance, with yield spread premiums paid to Midwest Financial for the higher-rate loan.
Wallace’s loan terms led to negative amortization, escalating payments, bankruptcy, and surrender of the home.
The district court granted summary judgment on several claims; Wallace appeals focusing on proximate causation and related theories.

Issue	Plaintiff's Argument	Defendant's Argument	Held
Proximate causation under RICO §1962(c)	Wallace	Midwest/MortgageIT	Proximate causation shown; remand for factual development
RICO conspiracy proximate-causation and elements	Wallace	Midwest/MortgageIT	Remand to district court to resolve elements of §1962(d)
Kentucky civil conspiracy causation	Wallace	Midwest/MortgageIT	Remand as to first subpart; second subpart rejected for lack of unlawful agreement

Holmes v. Sec. Investor Prot. Corp., 503 U.S. 258 (Supreme Court 1992) (proximate causation framework for RICO)
Sedima, S.P.R.L. v. Imrex Co., Inc., 473 U.S. 479 (Supreme Court 1985) (elements of RICO claim for predicate acts and enterprise)
Perry v. American Tobacco Co., Inc., 324 F.3d 845 (6th Cir. 2003) (proximate causation and foreseeability in RICO)
Anza v. Ideal Steel Supply Corp., 547 U.S. 451 (Supreme Court 2006) (relation between scheme and injury; reliance not required)
Trollinger v. Tyson Foods, Inc., 370 F.3d 602 (6th Cir. 2004) (flexible proximate-cause standards in causation analysis)
Cox v. Admin. U.S. Steel & Carnegie, 17 F.3d 1386 (11th Cir. 1994) (proximate cause not required to be sole cause)