In a surprising twist, Justice Neil Gorsuch aligned with the liberal bloc of the Supreme Court in the Medical Marijuana v. Horn ruling.
According to Newsweek, the majority found that the RICO Act's norms on "business or property" include recoveries from personal injuries leading to business or property losses.
The ruling arose from the infamous case Medical Marijuana v. Horn, which involved the civil implications of the Racketeer Influenced and Corrupt Organizations (RICO) Act. The case was decided this past Wednesday, marking a significant moment in U.S. legal interpretations.
Justice Amy Coney Barrett, who has previously stepped away from her conservative colleagues, penned the majority opinion. Her interpretation indicated that damages for personal injuries that affect business or property should not be excluded under the RICO Act's "business or property" requirement. This clarification by Justice Barrett allows individuals who have sustained personal injuries with subsequent impact on their business operations or property to claim losses under the stringent conditions of RICO.
Justice Clarence Thomas presented a dissenting opinion on the case. In addition, Justice Brett Kavanaugh, supported by Chief Justice John Roberts and Justice Samuel Alito, also diverged, maintaining a conservative view on the interpretation of the RICO Act.
The contentious issue primarily revolved around the interpretation of whether claims involving personal injuries that result in business or property loss should be eligible under RICO. Justice Kavanaugh argued this could lead to bending the categorical exclusion of personal injury lawsuits under RICO into business or property injury claims.
At the core of this case was Douglas Horn, a man who, after a crash in 2012, used a CBD product named "Dixie X," which purportedly contained "0% THC." Horn faced a career setback when he was dismissed following his refusal to attend a substance abuse program after THC was detected in his system during a standard drug test.
This incident led him to file a lawsuit, asserting that his professional demise and consequent economic loss were directly attributable to misleading product claims, thus falling under the purview of RICO's property damage claims.
Justice Amy Coney Barrett elaborated on the specific application of the RICO Act’s “business or property” requirement in her official statement:
For example, if the owner of a gas station is beaten in a robbery, he cannot recover for his pain and suffering. But if his injuries force him to shut his doors, he can recover for the loss of his business. In short, a plaintiff can seek damages for business or property loss regardless of whether the loss resulted from a personal injury.
Justice Brett Kavanaugh, expressing concern, predicted: The aftermath of the Court's opinion could be quite a mess, as courts grapple with RICO personal injury cases where the question is what losses qualify as business or property losses.
The Supreme Court's decision emphasized that the implications of personal injuries could indeed transcend straightforward medical costs or pain and suffering, touching on substantial financial stability and overall life quality impacts when interfacing with business or property interests.
This resolution sends back the Medical Marijuana v. Horn case for further proceedings, where the lower courts will apply the Supreme Court's majority opinion, vested in broadening the scope of what may constitute recoverable damages under RICO related to business or property damages stemming from personal injury.
Neil Gorsuch's decision to vote with the liberal justices and Justice Amy Coney Barrett on this has undoubtedly had a profound influence on the direction and interpretation of the RICO Act, in a case that intertwines legal precedents with the increasingly contentious debates surrounding drug policy and employment practices in America.
