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Project Curia
Supreme Court decisions
No. 23-365Apr 2, 2025Crime and Law EnforcementAffirmed

The question

Whether civil RICO categorically bars recovery for business or property losses that derive from a personal injury.

Medical Marijuana, Inc. v. Horn

What the Court decided

The Court held that a civil RICO plaintiff may recover treble damages for business or property loss even when that loss results from a personal injury. Section 1964(c) limits the kinds of harm a plaintiff can recover for, business or property harm rather than personal harm, but it does not bar recovery based on the cause of that harm. A plaintiff whose business or property is damaged may sue regardless of whether the damage flowed from a personal injury.

How the justices split

5-4
In favor 5Against 4
Barrett
Sotomayor
Kagan
Gorsuch
Jackson
Thomas
Kavanaugh
Roberts
Alito

The Court's opinion

Barrett, joined by Sotomayor, Kagan, Gorsuch, Jackson

Section 1964(c) authorizes suit for any person injured in his business or property. The ordinary meaning of injured is harmed or damaged, so a plaintiff whose business or property is harmed may recover. The business or property requirement restricts the kinds of harm that are recoverable and excludes recovery for harm to one's person, but it does not restrict the cause of the harm. A plaintiff may therefore seek damages for business or property loss regardless of whether that loss resulted from a personal injury. The Court did not decide whether consuming THC was a personal injury, whether business covers all aspects of employment, or the meaning of injured in his property.

Concurring

Jackson, writing alone

Jackson filed a concurring opinion. The syllabus records its filing but does not state its reasoning.

Dissenting

Thomas, writing alone

Thomas filed a dissenting opinion. The syllabus records its filing but does not state its reasoning.

Dissenting

Kavanaugh, joined by Roberts, Alito

Kavanaugh filed a dissenting opinion joined by Roberts and Alito. The syllabus records its filing but does not state its reasoning.

How we know · 5 sourced claims
  • The Court held that under civil RICO, Section 1964(c), a plaintiff may seek treble damages for business or property loss even if the loss resulted from a personal injury.

    Source: syllabus, Held

  • The sole question before the Court was whether civil RICO categorically bars recovery for business or property losses that derive from a personal injury.

    Source: syllabus, Held

  • The Court did not decide whether Horn suffered a personal injury when he consumed THC, whether business encompasses all aspects of employment, or the meaning of injured in his property.

    Source: syllabus, Held

  • Barrett delivered the opinion of the Court, joined by Sotomayor, Kagan, Gorsuch, and Jackson.

    Source: syllabus, lineup

  • Kavanaugh filed a dissenting opinion in which Roberts and Alito joined, and Thomas filed a separate dissenting opinion.

    Source: syllabus, lineup

Read the opinion on supremecourt.gov