Medical Marijuana v. Horn

Under the civil provision of RICO, 18 U. S. C. §1964(c), a plaintiff may recover for harm to business or property even if that harm resulted from a personal injury. Justice Amy Coney Barrett authored the opinion of the Court on behalf of the 5-4 majority. The phrase “injured in his business or property” refers to the type of harm a plaintiff can recover for, not the cause of that harm. The ordinary meaning of injury—harm or damage—applies. While the statute excludes recovery for personal injury (like pain and suffering), it does not also exclude economic consequences flowing from a personal injury. For example, if physical injury forces someone to close their business, they may still recover under RICO for the resulting business loss. The text does not support reading an "antecedent personal injury" bar into the statute. Arguments that “injury” should be interpreted narrowly to cover only tortious invasions of legal rights find no support in context, precedent, or the structure of RICO. The Court reaffirmed that the “business or property” limitation is distinct from the cause of harm and that RICO precedents use terms like injury, harm, and damage interchangeably. Other limits on RICO suits—such as the requirement of direct causation and a pattern of predicate acts—already cabin its scope. Concerns about overreach must be addressed by Congress, not the courts. Justice Ketanji Brown Jackson filed a concurring opinion. Justice Clarence Thomas filed a dissenting opinion. Justice Brett Kavanaugh filed a dissenting opinion, in which Chief Justice John Roberts and Justice Samuel Alito joined.