Circuit Watcher

06-35112 Canyon County v. Syngenta Seeds, Inc.
Before: William C. Canby, Jr., A. Wallace Tashima, and Consuelo M. Callahan, Circuit Judges.
TASHIMA, Circuit Judge: This case involves an Idaho county’s attempt to recover damages under the Racketeer Influenced and Corrupt Organizations Act (“RICO”), 18 U.S.C. §§ 1961-1968, for additional monies it claims to have expended on public health care and law enforcement services for undocumented immigrants.
.
Plaintiff-appellant Canyon County commenced this action against four companies and one individual under RICO’s civil enforcement provision, 18 U.S.C. § 1964(c), alleging that defendants engaged in an illegal scheme of hiring and/or harboring undocumented immigrant workers within the County, and that their actions forced the County to pay “millions of dollars for health care services and criminal justice services for the illegal immigrants.”
.
The district court concluded that the County did not have statutory standing under § 1964(c) because the County did not meet the threshold requirement that a civil plaintiff be “injured in his business or property” by reason of the alleged RICO violation. Consequently, the court dismissed the County’s complaint.
.
We have jurisdiction pursuant to 28 U.S.C. § 1291, and we affirm the district court. We agree with the district court that the County has failed to allege that it was injured in its business or property. We also conclude that, with respect to almost all of the defendants’ alleged RICO violations, the County cannot show that its claimed injuries were proximately caused by defendants’ conduct. For both of these reasons, the County lacks statutory standing to pursue its federal RICO claims. … Canyon County v. Syngenta Seeds, Inc.