医用大麻公司诉霍恩案

Douglas Horn, a commercial truck driver, purchased and consumed "Dixie X," a CBD tincture marketed by Medical Marijuana, Inc. as THC-free. After a random drug test detected THC in his system, Horn was fired. He sued under the Racketeer Influenced and Corrupt Organizations Act (RICO), alleging that the company's false advertising caused his job loss. The District Court granted summary judgment to Medical Marijuana, ruling that Horn's lost employment derived from a personal injury (ingesting THC) and thus was not recoverable under RICO. The Second Circuit reversed, holding that job loss constituted an injury to business. The Supreme Court granted certiorari to resolve a circuit split regarding whether civil RICO categorically bars recovery for business or property losses that derive from personal injuries.

The Supreme Court affirmed the Second Circuit's judgment in a 5-4 decision. Justice Barrett delivered the majority opinion, joined by Justices Sotomayor, Kagan, Gorsuch, and Jackson. The Court held that under civil RICO, a plaintiff may seek treble damages for business or property loss even if the loss resulted from a personal injury. Justice Jackson filed a concurring opinion. Justice Thomas filed a dissenting opinion; Justice Kavanaugh filed a dissenting opinion joined by Chief Justice Roberts and Justice Alito. The case was remanded for further proceedings.

Whether economic harms resulting from personal injuries qualify as injuries to "business or property" under 18 U.S.C. § 1964(c) for purposes of a civil RICO treble-damages action. The central question was whether civil RICO categorically bars recovery for business or property losses that derive from a personal injury.

The decision resolved a circuit split and significantly expanded the scope of civil RICO, holding that economic harms are recoverable even when they stem from personal injuries. The ruling has major implications for consumer protection, human trafficking victims' rights, the hemp industry, and businesses facing RICO claims. It rejected the "antecedent-personal-injury bar" that several circuits had previously adopted. The 5-4 split reflects ongoing judicial debate over the proper scope of RICO's civil remedy provision.