Horn v. Med. Marijuana, Inc., 80 F.4th 130 (Decided April 2, 2025) Barrett, Justice.
Justice Barrett delivered the opinion of the Court.
The Racketeer Influenced and Corrupt Organizations Act (RICO) creates a cause of action for “[a]ny person injured in his business or property.” 18 U. S. C. §1964(c). We must decide whether the statute, by implicitly denying a remedy for personal injuries, also denies a remedy for business and property loss that derives from a personal injury. It does not.
Medical Marijuana, together with the principal dissent, warn that the Second Circuit’s rule will eviscerate RICO’s “business or property” limitation. See post, at 12 (opinion of Kavanaugh, J.). In their view, a plaintiff can characterize any economic harm flowing from a personal injury as a harm to his business or property. Hence, they say, plaintiffs can easily transform garden-variety personal-injury claims into RICO suits for treble damages. While we understand the concern, Medical Marijuana and the dissent understate other constraints on civil RICO claims.
First and foremost is RICO’s direct-relationship requirement. Time and again, we have reiterated that §1964(c)’s “by reason of ” language demands “some direct relation between the injury asserted and the injurious conduct alleged.” Holmes, 503 U. S., at 268. The key word is “direct”; foreseeability does not cut it. Hemi Group, 559 U. S., at 12. Rather, whenever the plaintiff ’s theory of causation requires moving “well beyond the first step,” it “cannot meet RICO’s direct relationship requirement.” Id., at 10.
Given the number of steps in Horn’s theory and the multiple actors involved, this requirement may present an insurmountable obstacle in his case. Indeed, even Horn concedes that he faces “a heavy burden on remand.” There is, after all, some distance between the first link in the chain (Medical Marijuana’s misrepresentations) and the last (Horn’s job loss).
Second, pleading a RICO claim is not as simple as pointing to a business or property harm. A plaintiff must first establish a pattern of racketeering activity. 18 U. S. C. §§1962, 1964(c). Doing so requires identifying two or more predicate crimes “within a single scheme that were related and that amounted to, or threatened the likelihood of, continued criminal activity.” H. J. Inc. v. Northwestern Bell Telephone Co., 492 U.S. 229, 237 (1989); see also §§1961(1) and (5), 1962. So harm resulting from a single tort is not a ticket to federal court for treble damages.
Third, the reach of §1964(c) turns on more than the meaning of “injured.” As we noted at the outset, “business” may not encompass every aspect of employment, and “property” may not include every penny in the plaintiff ’s pocketbook. Accordingly, not every monetary harm—be it lost wages, medical expenses, or otherwise—necessarily implicates RICO. Medical Marijuana brushes away this possibility, instead attributing the broadest definitions to both terms.
All of this said, civil RICO has undeniably evolved “into something quite different from the original conception of its enactors.” Sedima, 473 U. S., at 500. More suits are brought against ordinary businesses than against “archetypal, intimidating mobster[s],” id., at 499, and given this development, Medical Marijuana is not the first litigant to express concern about “the ‘over-federalization’ of traditional state-law claims,” Bridge, 553 U. S., at 659. But we respond today as we have before: If the breadth of the statute “leads to the undue proliferation of RICO suits, the ‘correction must lie with Congress.’ ” Id., at 660 (quoting Sedima, 473 U. S., at 499); see also H. J. Inc., 492 U. S., at 248–249; Boyle v. United States, 556 U.S. 938, 950–951 (2009).
The phrase “injured in his business or property” does not preclude recovery for all economic harms that result from personal injuries. We therefore affirm the Second Circuit’s judgment and remand the case for further proceedings consistent with this opinion.
