What is the test for proving proximate cause for a civil claim under the RICO Act?

MultiRegion, United States of America

The following excerpt is from 7 W. 57th St. Realty Co. v. Citigroup, Inc., 18-1102-cv (2nd Cir. 2019):

"[T]o state a claim under civil RICO, the plaintiff is required to show that a RICO predicate offense not only was a 'but for' cause of his injury, but was the proximate cause as well." Hemi Grp., LLC v. City of New York, 559 U.S. 1, 9 (2010) (internal quotation marks omitted). "Proximate cause for RICO purposes . . . should be evaluated in light of its common-law foundations; proximate cause thus requires some direct relation between the injury asserted and the injurious conduct alleged. A link that is too remote, purely contingent, or indirec[t] is insufficient." Id. (second alteration in original) (citation and internal quotation marks omitted).

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