Supreme Court Spotlight: Medical Marijuana Inc. v. Horn and the Expanding Reach of RICO
This article reviews: Darcangelo, D. Redefining Injury: RICO, Employment Loss, and Corporate Accountability in Medical Marijuana Inc. v. Horn. (2025) doi:10.2139/ssrn.5286974.
When it comes to cannabis litigation, few cases capture the intersection of product labeling, consumer harm, and federal racketeering law (RICO) as dramatically as Medical Marijuana Inc. v. Horn. According to D'Arcangelo-McDonald (2025) this Supreme Court decision raises profound questions about corporate accountability and sets the stage for future expert witness testimony in cannabis-related lawsuit.
Background of the Case
Elijah Horn, a commercial truck driver injured in 2012, turned to a CBD product marketed as “Dixie X” for relief. Unbeknownst to him, the product contained undisclosed THC. When a mandatory drug test returned positive, Horn lost his job. He filed suit against Medical Marijuana Inc. and its affiliates, arguing under RICO statutes that his economic losses stemmed from mislabeling and deceptive practices.
The District Court initially sided with the company, claiming Horn’s damages were tied to personal injury, not business or property. However, the Second Circuit reversed, holding that employment loss can qualify as an injury under RICO—even if the harm originated from personal injury. The Supreme Court then weighed in with a narrow 5–4 ruling in Horn’s favor.
Why This Case Matters for Litigation
This case has broad implications for civil litigation, consumer protection, and expert testimony in cannabis cases:
RICO Expansion: The ruling affirms that economic losses tied to mislabeled cannabis products may qualify as recoverable injuries under federal law.
Corporate Accountability: Companies can be held liable for inaccurate THC/CBD content claims, reinforcing the need for compliance and reliable laboratory testing.
Role of Expert Witnesses: Courts increasingly rely on scientific and regulatory experts to establish what companies “should have known” about product contents and risks. This highlights the importance of credible experts in toxicology, pharmacology, labeling standards, and cannabis regulations.
The Legal Divide
The decision was anything but unanimous. Justice Amy Coney Barrett’s majority opinion stressed that the statutory language of “injury to business or property” encompasses economic losses, regardless of origin. Justice Clarence Thomas dissented, warning that such expansion could overwhelm courts with personal injury tort claims rebranded as RICO actionsssrn-5286974.
Amicus briefs reflected this divide:
The U.S. Chamber of Commerce warned of excessive litigation and international business strain.
The American Association for Justice supported Horn, framing the decision as necessary for protecting consumers.
The U.S. Hemp Roundtable raised concerns about ripple effects on the hemp market, where product mislabeling is a recurring issue.
Key Takeaways for Attorneys and Courts
For lawyers, regulators, and industry professionals, Medical Marijuana Inc. v. Horn underscores several takeaways:
Testing & Labeling Are Litigation Risks – Failure to ensure accurate cannabinoid content creates exposure to RICO and civil liability.
Expert Witnesses Are Critical – Both plaintiffs and defendants needed authoritative testimony to explain testing methods, labeling standards, and the pharmacological impacts of THC and CBD.
Employment Consequences Are Actionable – Loss of a job tied to mislabeled cannabis products may qualify as injury under RICO.
Conclusion
The Medical Marijuana Inc. v. Horn ruling represents a landmark moment in cannabis litigation, expanding the scope of RICO to cover economic damages tied to mislabeled cannabis products. For attorneys preparing cases, and for courts evaluating scientific evidence, the role of the expert witness has never been more important.
As cannabis products continue to grow in popularity and complexity, so too will the demand for expert testimony that bridges the gap between science, law, and consumer protection.
The information provided in this article is for educational and informational purposes only and does not constitute legal advice. Reading this post does not create an attorney–client relationship. Individuals or businesses facing hemp or cannabis-related litigation should consult with a qualified attorney for advice regarding their specific situation.
