From Kalomiris v. Monroe County Syndicate, 2009 U.S. Dist. LEXIS 1264 (M.D. Pa. Jan. 8, 2009):
RICO requires that the plaintiff sustain injury to "business or property." 18 U.S.C. § 1964(c). Personal injuries, loss of earnings, and other indirect injuries do not confer standing under RICO. See Anderson v. Ayling, 396 F.3d 265, 270-71 (3d Cir. 2005) (upholding dismissal of the plaintiffs' RICO claims because the complaint failed to allege a direct, causal link between the plaintiff's loss of employment and the alleged racketeering activity); Genty v. Resolution Trust Corp., 937 F.2d 899, 918-19 (3d Cir. 1991) (concluding that personal injuries cannot confer standing under RICO). ***
[Footnote 17.] Loss of employment may confer RICO standing if the alleged racketeering activity proximately caused the plaintiff's harm. See, e.g., Genty, 937 F.2d at 918 n.12 ("[T]he loss of employment due to racketeering activity is injury to "business" not personal injury and so resulting loss of wages, benefits, and damage to reputation are compensable under section 1964(c)."); Magnum v. Archdiocese of Phila. , No. 06-CV-2589, 2006 WL 3359642, at *3 n.3 (E.D. Pa. Nov. 17, 2006). An attenuated or speculative relationship between the alleged racketeering activity and the plaintiff's harm cannot sustain RICO liability. See Anderson, 396 F.3d at 270.
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