Source: cases/18usc1962/us-604-593-medical-marijuana-v-horn.case
Case source: https://www.neochart.com/catalog/cases/clus/volume_604/593/index.html
But the “business or property” requirement operates with respect to the kinds of harm for which the plaintiff can recover, not the cause of the harm for which he seeks relief.
In short, a plaintiff can seek damages for business or property loss regardless of whether the loss resulted from a personal injury.
The phrase “injured in his business or property” does not preclude recovery for all economic harms that result from personal injuries.
casedsl 1.2 # author: Flash1 (gemini-3.8-flash-high) # triaged-by: Fable (2026-11-10) case /us/604/593 name Medical Marijuana, Inc. v. Horn cite 604 U.S. 593 (2025) court Supreme Court of the United States date 2025-04-02 url catalog/cases/clus/volume_604/593/index.html source ir/caselaw/clus_604.jsonl sha1=81f06c394c039dd4125a15e1226748baa6f0f299 chars=59999 opinion maj : majority by Barrett @9994..47919 controlling opinion con : concurrence by Jackson @47920..48690 opinion dis : dissent by Thomas @48691..59999 ? opinion: IR text is capped at 59999 chars inside Thomas's dissent; Kavanaugh's principal dissent is not in the record party horn : Douglas Horn, commercial truck driver fired after a drug test (plaintiff; respondent) party mmi : Medical Marijuana, Inc. and co-defendants, sellers of "Dixie X" (petitioners) count c1 : civil RICO treble-damages claim, § 1964(c) theory t1 : business or property loss deriving from a personal injury law 18usc1962 role applied posture civil; truck driver sued CBD seller under civil RICO § 1964(c) alleging false "0% THC" marketing led to a failed drug test and loss of his job; district court granted summary judgment for defendants (loss derivative of a personal injury); CA2 reversed; Supreme Court affirmed and remanded result claimant-won element injury : satisfied [law] route business-or-property pattern lost employment flowing from unwitting ingestion of THC (assumed to be an antecedent personal injury) party horn mmi count c1 theory t1 fact @12560..12719 [supports] | After Horn refused to complete a substance- abuse program—in his view, doing so would constitute “an admission to doing drugs,” id., at 91–92—his employer fred fact @14306..14499 [neutral] | According to the court, Horn's lost employment “fow[ed] from, and [was] derivative of, a personal injury he suffered”—the introduction of THC “into his system through the ingestion of Dixie X.” rule @20612..20787 | But the “business or property” requirement operates with respect to the kinds of harm for which the plaintiff can recover, not the cause of the harm for which he seeks relief. rule @20999..21131 | In short, a plaintiff can seek damages for business or property loss regardless of whether the loss resulted from a personal injury. held @47642..47776 | The phrase “injured in his business or property” does not preclude recovery for all economic harms that result from personal injuries. gloss Only the antecedent-personal-injury bar is decided (rejected). The Court assumed that Horn suffered a personal injury and left untouched the Second Circuit's unchallenged ruling that lost employment is injury to "business"; proximate cause was flagged as a possibly insurmountable obstacle on remand. ? holding: `satisfied [law]` records that the element is not defeated as a matter of law by the personal-injury origin of the loss; the Court expressly did NOT decide whether "business" covers employment or what "property" covers, so the element is not finally established. ? polarity: the derivative-of-personal-injury finding is the defendant's whole case against the element, but the Court held the cause of the harm legally irrelevant -- hence [neutral].