Beck v. Prupis

Summary

The Court held that a civil RICO conspiracy claim cannot rest on injury caused by an overt act that is neither racketeering activity nor otherwise unlawful under RICO. Drawing on common-law civil conspiracy principles, Justice Thomas explained that the injurious act must be independently wrongful under RICO; Beck’s termination did not satisfy that requirement. The Court affirmed the Court of Appeals. Justice Stevens, joined by Justice Souter, dissented, arguing that the statutory text permits recovery for injury proximately caused by any overt act furthering an unlawful RICO conspiracy and that the majority’s common-law authorities did not establish its additional restriction.