The federal Racketeer Influenced and Corrupt
Organization (RICO) provision creates a civil cause of action for any person or entity injured in their
business or property by reason of a RICO violation. In Anza v. Ideal Steel Supply Corporation, the
Supreme Court relied on Holmes v. Securities Investor Protection Corporation and held that to
establish standing under this civil RICO provision, a plaintiff must demonstrate that he or she was
the direct victim of the defendant's RICO violation, e.g., a business may not sue a competitor that
may have gained a competitive advantage by not paying taxes. The Court explained that this
construction will save district courts from the difficulty of determining an indirect victim's damages
caused by attenuated conduct. This decision may have implications for the plaintiffs in Mohawk
Industries v. Williams, a suit brought by employees under RICO for employment violations of the
Immigration and Nationality Act. On the same day as its decision in Ideal, the Supreme Court
remanded Mohawk for reconsideration in light of its holding in Ideal.(1)