Medical Marijuana, Inc. v. Horn (Civil RICO)

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In Medical Marijuana, Inc. v. Horn, the Supreme Court affirmed the Second Circuit and held that a plaintiff may seek treble damages under the civil RICO statute for injuries to business or property, even if those injuries stem from a personal injury. Douglas Horn was fired after testing positive for THC, allegedly caused by using a CBD product marketed as THC-free. He sued the manufacturer under RICO, claiming his job loss constituted a business injury. The district court dismissed the case, applying the so-called “antecedent personal injury bar,” which precludes recovery under RICO for business losses resulting from personal injury. The Second Circuit reversed.

Writing for the Court, Justice Barrett rejected the categorical bar. The Court held that while civil RICO does not authorize damages for personal injuries themselves, it does not exclude claims for business or property losses merely because they originate from a personal injury. Drawing on the statute’s text, the Court emphasized the ordinary meaning of “injured in his business or property” and declined to import tort-based limitations or narrow definitions unsupported by the statutory language. The Court also declined to adopt a rigid rule for distinguishing personal from business injuries, finding such distinctions difficult to apply and inconsistent with prior precedent.

Justice Barrett delivered the opinion of the Court, joined by Justices Sotomayor, Kagan, Gorsuch, and Jackson. Justice Jackson filed a concurring opinion. Justice Thomas dissented. Justice Kavanaugh filed a dissenting opinion, joined by Chief Justice Roberts and Justice Alito.

Read by RJ Dieken.