Medical Marijuana, Inc. v. Horn — 604 U.S. 593 (2025) · Supreme Court of the United States · 2025

Supreme Court of the United States · 2025-04-02

18usc1962: author: Flash1 · QA: FIX (Fable, neov2/cases/TRIAGE-Flash.md)

Original case on neochart.com

Case and law context

18 U.S.C. § 1962

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; claim:

Uncertainty

opinion: IR text is capped at 59999 chars inside Thomas's dissent; Kavanaugh's principal dissent is not in the record

Element injury: 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.

Element injury: 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].

Misfit

None recorded

B · Case × element grid

Top-level elements follow claim order in panels of up to six elements. Case rows repeat across panels. Every recorded block retains its holding and basis; multiple blocks are not merged into a case-level verdict. ✓ satisfied · ✗ not satisfied · ○ not reached · · not addressed. Muted blocks are not counted. Sub-element evidence remains on case and element pages.

Elements 1–6 of 19

18 U.S.C. § 1962
CaseCulpable person (§ 1961(3)) distinct from the enterprise under (c)Pattern of racketeering activity (§ 1961(5)): at least two predicate acts with relatedness and continuityRacketeering activity (§ 1961(1) enumerated state and federal predicate offenses)Collection of an unlawful debt (§ 1961(6)) — alternative to pattern of racketeering activityUse or investment of racketeering income in an enterprise (§ 1962(a))Enterprise (§ 1961(4)): legal entity or association-in-fact
Medical Marijuana, Inc. v. Horn — 604 U.S. 593 (2025) · Supreme Court of the United States · 2025 (18usc1962: author: Flash1 · QA: FIX (Fable, neov2/cases/TRIAGE-Flash.md))· not addressed· not addressed· not addressed· not addressed· not addressed· not addressed

Elements 7–12 of 19

18 U.S.C. § 1962
CaseInterstate or foreign commerce nexusDe minimis open-market securities investment proviso (§ 1962(a))Acquire or maintain interest in or control of an enterprise (§ 1962(b))Defendant employed by or associated with the enterprise (§ 1962(c))Conduct or participate in the conduct of enterprise affairs (§ 1962(c) operation or management test)Conspiracy to violate § 1962(a), (b), or (c) (§ 1962(d))
Medical Marijuana, Inc. v. Horn — 604 U.S. 593 (2025) · Supreme Court of the United States · 2025 (18usc1962: author: Flash1 · QA: FIX (Fable, neov2/cases/TRIAGE-Flash.md))· not addressed· not addressed· not addressed· not addressed· not addressed· not addressed

Elements 13–18 of 19

18 U.S.C. § 1962
CaseCivil RICO injury to business or property (18 U.S.C. § 1964(c))But-for and proximate causation ("by reason of", 18 U.S.C. § 1964(c))Statute of limitations (4-year civil under Agency Holding; 5-year criminal under 18 U.S.C. § 3282)Claim preclusion / release by prior class-action settlementCivil aiding and abetting a RICO violation (rejected as a private cause of action)Fifth Amendment Double Jeopardy bar against successive RICO conspiracy/substantive prosecutions
Medical Marijuana, Inc. v. Horn — 604 U.S. 593 (2025) · Supreme Court of the United States · 2025 (18usc1962: author: Flash1 · QA: FIX (Fable, neov2/cases/TRIAGE-Flash.md))· not addressed· not addressed· not addressed· not addressed· not addressed

Elements 19–19 of 19

18 U.S.C. § 1962
CaseParol evidence rule raised to bar extrinsic evidence of fraudulent misrepresentations
Medical Marijuana, Inc. v. Horn — 604 U.S. 593 (2025) · Supreme Court of the United States · 2025 (18usc1962: author: Flash1 · QA: FIX (Fable, neov2/cases/TRIAGE-Flash.md))· not addressed

Instances and excluded annotation blocks

Annotation blocks, including explicitly excluded context
CaseElementHolding and scopePatternExact source quotations
Medical Marijuana, Inc. v. Horn — 604 U.S. 593 (2025) · Supreme Court of the United States · 2025 — satisfied · law (18usc1962: author: Flash1 · QA: FIX (Fable, neov2/cases/TRIAGE-Flash.md))Civil RICO injury to business or property (18 U.S.C. § 1964(c))satisfied
Counted merits instance
applied / merits

basis: law; party: Douglas Horn, commercial truck driver fired after a drug test (plaintiff; respondent); Medical Marijuana, Inc. and co-defendants, sellers of "Dixie X" (petitioners); count: civil RICO treble-damages claim, § 1964(c); theory: business or property loss deriving from a personal injury; subject: party=Douglas Horn, commercial truck driver fired after a drug test (plaintiff; respondent); Medical Marijuana, Inc. and co-defendants, sellers of "Dixie X" (petitioners); count=civil RICO treble-damages claim, § 1964(c); theory=business or property loss deriving from a personal injury

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.
lost employment flowing from unwitting ingestion of THC (assumed to be an antecedent personal injury)
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
Source: docroot/ir/caselaw/clus_604.jsonl#/us/604/593; Unicode character offsets [12560:12719] (end exclusive); SHA-256 7d2c2919066c4147ebeda30dba0ab8417dc2b1c103398f9c66191df2e5bf6392.

Evidence kind: fact; polarity: supports; absent flag: 0; quoted-rule flag: 0 (1 = tagged; 0 = not tagged)

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.
Source: docroot/ir/caselaw/clus_604.jsonl#/us/604/593; Unicode character offsets [20612:20787] (end exclusive); SHA-256 7d2c2919066c4147ebeda30dba0ab8417dc2b1c103398f9c66191df2e5bf6392.

Evidence kind: rule; polarity: not recorded; absent flag: 0; quoted-rule flag: 0 (1 = tagged; 0 = not tagged)

In short, a plaintiff can seek damages for business or property loss regardless of whether the loss resulted from a personal injury.
Source: docroot/ir/caselaw/clus_604.jsonl#/us/604/593; Unicode character offsets [20999:21131] (end exclusive); SHA-256 7d2c2919066c4147ebeda30dba0ab8417dc2b1c103398f9c66191df2e5bf6392.

Evidence kind: rule; polarity: not recorded; absent flag: 0; quoted-rule flag: 0 (1 = tagged; 0 = not tagged)

The phrase “injured in his business or property” does not preclude recovery for all economic harms that result from personal injuries.
Source: docroot/ir/caselaw/clus_604.jsonl#/us/604/593; Unicode character offsets [47642:47776] (end exclusive); SHA-256 7d2c2919066c4147ebeda30dba0ab8417dc2b1c103398f9c66191df2e5bf6392.

Evidence kind: held; polarity: not recorded; absent flag: 0; quoted-rule flag: 0 (1 = tagged; 0 = not tagged)

Court interpretations recorded from this case

interpretation

479, 497 (“[T]he compensable injury necessarily is the harm caused by predicate acts suffciently related to constitute a pattern”); Anza v.

Medical Marijuana, Inc. v. Horn — 604 U.S. 593 (2025) · Supreme Court of the United States · 2025 (18usc1962: author: Flash1 · QA: FIX (Fable, neov2/cases/TRIAGE-Flash.md))

479, 497 (“[T]he compensable injury necessarily is the harm caused by predicate acts suffciently related to constitute a pattern”); Anza v.
Source: docroot/ir/caselaw/clus_604.jsonl#/us/604/593; Unicode character offsets [5466:5605] (end exclusive); SHA-256 7d2c2919066c4147ebeda30dba0ab8417dc2b1c103398f9c66191df2e5bf6392.

Damages must be concrete, clear, and definite (not speculative or unripe pending exhaustion of contractual/collateral remedies), and must be domestic under RJR Nabisco v. European Community (579 U.S. 325 (2016)).