Yegiazaryan v. Smagin

Summary

The Court held that whether a civil RICO plaintiff alleges a domestic injury depends on the circumstances surrounding the injury, not categorically on the plaintiff’s residence. Smagin adequately alleged a domestic injury because racketeering activity largely occurring in or directed from California impaired his ability to enforce a California judgment against a California resident. The Court affirmed the Ninth Circuit and remanded. Justice Sotomayor wrote for six Justices, joined by Chief Justice Roberts and Justices Kagan, Kavanaugh, Barrett, and Jackson. Justice Alito dissented, joined by Justice Thomas and, as to Part I, Justice Gorsuch. The dissent would have dismissed the writs as improvidently granted because the contextual test provided insufficient guidance; Alito and Thomas also warned that the decision risked inconsistency with the Court’s extraterritoriality precedents.