Craft & Sheppard's Supreme Court Review
Racketeer Influenced & Corrupt Organizations Act (RICO)
RICO, 18 U.S.C. § 1961, gives a private treble damage action to a person injured in his “business or property” “by reason of a violation” of its criminal prohibitions, § 1964(c). When a RICO suit alleges mail fraud as the predicate act, in Bridge v. Phoenix Bond & Indem. Co. the Court ruled that a plaintiff need not show reliance on defendant’s misrepresentations either as an element of the claim or as a prerequisite to establish proximate cause.
