Brown v. Ajax Paving Indus., Inc.

Brown claimed that he injured his shoulder while paving a road for his employer Ajax Paving, and sought workers’ compensation. Ajax introduced medical testimony suggesting that the injury occurred outside of work. While the case remained pending before the Michigan administrative agency, Brown and Ajax settled. Brown, however, thought that Ajax had introduced false medical testimony and that it had done the same to other employees, and sued Ajax and its insurers, claims administrators and the doctor, under the Racketeer Influenced and Corrupt Organizations Act, 18 U.S.C. 1964(c). The district court dismissed. The Sixth Circuit affirmed. Under the Act, Brown must show that illegal racketeering activities have “injured [him] in his business or property.” The Sixth Circuit has held that “loss or diminution of benefits the plaintiff expects to receive under a workers’ compensation scheme does not constitute an injury to ‘business or property’ under RICO.” View "Brown v. Ajax Paving Indus., Inc." on Justia Law