Plain-English summary
Court affirms RICO requires direct injury to business or property, not derivative economic losses from personal injury
The Court held that RICO’s civil-damages provision does not cover purely economic harms that flow from personal injuries. The judgment for respondent Douglas Horn was affirmed and the case remanded.
Why this matters
This decision limits who can bring civil RICO suits for treble damages. Plaintiffs cannot use RICO to recover ordinary economic losses that result from someone’s personal injury; they must show an injury directly to their business or property. That narrows the statute’s civil reach and affects many claims that have relied on RICO to seek large treble damages for economic fallout from harms to people.
Who may feel it
- Plaintiffs seeking treble damages under RICO for economic losses tied to personal injuries
- Businesses and individuals sued under RICO for conduct causing physical harm to others
- Litigators, insurers, and victims’ advocacy groups who bring or defend civil RICO claims
- Lower courts handling RICO standing and causation disputes
Key questions
- Does an economic loss that flows from another person’s physical injury qualify as an injury “to business or property” under RICO’s civil-damages provision?