Medical Marijuana, Inc. v. Horn

604 U.S. 593 (2025) Supreme Court of the United States 2025-04-02

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)

Facts

  1. 12 Civil RICO injury to business or property (18 U.S.C. § 1964(c)) satisfied law
    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
  2. 12 Civil RICO injury to business or property (18 U.S.C. § 1964(c)) satisfied law
    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.
  3. 12 Civil RICO injury to business or property (18 U.S.C. § 1964(c)) satisfied law
    In short, a plaintiff can seek damages for business or property loss regardless of whether the loss resulted from a personal injury.
  4. 12 Civil RICO injury to business or property (18 U.S.C. § 1964(c)) satisfied law
    The phrase “injured in his business or property” does not preclude recovery for all economic harms that result from personal injuries.