Williams v. Hall

Summary

The court considered defendants' motions for summary judgment in consolidated wrongful-discharge actions brought by former Ashland Oil officers who alleged that the company engaged in bribery and related racketeering activity. The court held that plaintiffs could pursue civil claims under the RICO conspiracy provision, 18 U.S.C. § 1962(d), if they proved that their discharges were overt acts in furtherance of the conspiracy and caused them injury, even if the discharges were not themselves predicate acts. The motions for summary judgment on the RICO claims were denied.

Holdings

1. A plaintiff who proves a conspiracy to violate 18 U.S.C. § 1962(a) or (c) may recover under 18 U.S.C. § 1964(c) by showing injury caused by any overt act committed pursuant to or in furtherance of the conspiracy; the injury-causing overt act need not itself be a RICO predicate act.

Questions Presented

1. Whether plaintiffs had standing to bring civil RICO claims under 18 U.S.C. §§ 1962(a) and (c) when their alleged injury from discharge was indirect rather than directly caused by predicate racketeering acts.
2. Whether a plaintiff who proves a conspiracy to violate RICO under 18 U.S.C. § 1962(d) may recover under § 1964(c) for injury caused by overt acts committed in furtherance of the conspiracy, even when those overt acts are not themselves statutory predicate acts.

Disposition

other