Supreme Court Decides Medical Marijuana, Inc. v. Horn

On April 2, 2025, the Supreme Court of the United States issued a decision in Medical Marijuana, Inc. v. Horn, No. 23-365, holding that the RICO civil cause of action for “[a]ny person injured in his business or property,” 18 U.S.C. § 1964(c), extends to injuries to business or property that derive from personal injuries.

Respondent, suffering from chronic pain, purchased and ingested a product named “Dixie X,” which Petitioner marketed and sold as “0% THC.” Respondent was then selected for random drug screening by his employer. He tested positive for THC.

Respondent filed suit under Section 1964(c) and related statutes, alleging Petitioner’s marketing, distribution, and sale of Dixie X constituted a RICO enterprise engaged in a pattern of racketeering activity. The district court ruled against Respondent, holding that Section 1964(c) only redresses injuries to “business or property,” excluding personal injuries, and therefore does not extend to injuries to business or property that derive from a personal injury (here, ingesting THC). The Second Circuit reversed, declining to adopt the district court’s reading of Section 1964(c), holding that business and property are no less injured when the injury flows from “an antecedent personal injury.”

The Supreme Court affirmed the holding of the Second Circuit. The Supreme Court rejected the argument that an injury to “business or property” was limited to an “invasion of a business or property right,” thus always precluding RICO claims under Section 1964(c) that arise out of a personal-injury tort. The Supreme Court looked to the meaning of “injury,” which can mean both an invasion of a legal right as well as harm or damage, and held that when a statute uses a word that confers both ordinary and specialized meanings, courts are guided by the overall statutory context. The Supreme Court concluded that the statutory context surrounding Section 1964(c) contemplated that the term “injury” was to be used in its ordinary, broader meaning.

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