Medical Marijuana v. Horn

In Medical Marijuana v. Horn, the Supreme Court affirmed a Second Circuit ruling that allowed Douglas Horn to pursue a civil claim under the Racketeer Influenced and Corrupt Organizations Act (RICO) (RICO). Horn, a truck driver, lost his job after failing a drug test for THC, which he claimed was present in a CBD-based medication he used for pain relief. He sued the manufacturers, alleging deceptive business practices and fraudulent inducement. While lower courts dismissed his RICO claim, ruling his job loss was a personal injury, the Second Circuit found that the loss of employment, salary, and pension constituted business or property damage. The Supreme Court agreed, stating that RICO allows claims for business and property loss that stems from a personal injury.12