Medical Marijuana, Inc. v. Horn

In this case, the court considered this issue: Are economic harms resulting from personal injuries properly considered injuries to “business or property by reason of” the defendant’s acts for purposes of a civil treble-damages action under the Racketeer Influenced and Corrupt Organizations Act?The case was decided on April 2, 2025.The Supreme Court, in a 5-4 decision authored by Justice Amy Coney Barrett, upheld the Second Circuit's ruling that Horn's loss of employment and associated economic damages qualified as injuries to "business or property" under RICO. The majority concluded that the statute permits recovery for economic harms directly resulting from racketeering activities, even if those harms stem from personal injuries. Justice Barrett emphasized that "injured" in the context of RICO simply means "harmed," and thus, economic losses like lost wages are recoverable. citeturn0news12Justice Ketanji Brown Jackson concurred, highlighting that RICO should be liberally construed to effectuate its remedial purposes. In dissent, Justice Brett Kavanaugh, joined by Chief Justice John Roberts and Justice Samuel Alito, expressed concern that this interpretation could broaden RICO's scope to include traditional personal injury claims, potentially federalizing state tort law. Justice Clarence Thomas also dissented separately, suggesting the case should have been dismissed as improvidently granted. The opinion is presented here in its entirety, but with citations omitted. If you appreciate this episode, please subscribe. Thank you.