604 U.S. 593 (2025) · 2025
Medical Marijuana, Inc. v. Horn
civil RICOconsumer protectioncannabis industryproduct labelingemployment lossLandmark
Summary
The Court held that a plaintiff may seek civil RICO damages for injury to business or property even when the economic harm flows from a personal injury. Horn's lost employment income could qualify as injury to business or property if he proves the rest of his claim.
Background & Context
RICO lets private plaintiffs sue for injuries to business or property caused by racketeering activity. Horn alleged deceptive marketing caused him to ingest THC unknowingly and lose his job. The dispute centered on whether economic losses linked to personal injury are categorically outside civil RICO.
The Question Before the Court
Can civil RICO cover business or property losses that result from a personal injury?
Petitioner
Medical Marijuana, Inc., et al.
Party asking the Court to review or reverse
Argued
- Economic loss to business or property is recoverable.
Respondent
Douglas J. Horn
Party defending the judgment below
Argued
- RICO does not cover personal-injury-derived losses.
The Holding
Civil RICO's private right of action for injury to business or property can cover business or property losses that flow from a personal injury; the statute does not categorically bar recovery for economic harm because the harm stems from a personal injury.
The Court
How the justices lined up in this decision.
5-4
Vote
Joined decision
5 justicesAC
Amy Barrett
Majority
EK
Elena Kagan
Majority
KB
Ketanji Jackson
Majority
NG
Neil Gorsuch
Majority
SS
Sonia Sotomayor
Majority
Dissented
4 justicesBK
Brett Kavanaugh
Dissent
CT
Clarence Thomas
Dissent
JR
John Roberts
Dissent
SA
Samuel Alito
Dissent
What this means for you
The ruling expands civil RICO exposure for businesses accused of deceptive marketing when plaintiffs can show lost wages or other property losses. It matters for cannabis and CBD companies, workers subject to drug testing, and consumers who rely on product-label claims. It does not let plaintiffs recover for personal injuries themselves under RICO; the injury must be to business or property.
Key Takeaways
- The Court rejected a categorical bar on economic losses flowing from personal injury.
- The case involved a CBD product allegedly marketed as THC-free.
- The plaintiff alleged he lost his truck-driving job after failing a drug test.
- The ruling does not make personal injuries themselves recoverable under civil RICO.
- The decision increases legal risk for businesses accused of fraudulent product claims that cause economic loss.
Decision
5-4 majority opinion
- Citation
- 604 U.S. 593 (2025)
- Vote
- 5-4
- Decision type
- Majority opinion
- Argued
- October 15, 2024
- Decided
- April 2, 2025
- Term
- 2024
- Opinion author
- Amy Coney Barrett
Justice Barrett wrote the Court's opinion, joined by Justices Sotomayor, Kagan, Gorsuch, and Jackson. Justice Jackson concurred. Justice Thomas dissented. Justice Kavanaugh dissented, joined by Chief Justice Roberts and Justice Alito.