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United States Supreme Court
Mohawk Industries v. Williams (Docket
Employee vs. employer civil RICO case remanded to the 11th Circuit.
June 5, 2006
The writ of certiorari limited to Question 1 presented by the petition, granted at 546 U. S. ___ (2005), is dismissed as improvidently granted. The petition for a writ of certiorari is granted. The judgment is vacated, and the case is remanded to the United States Court of Appeals for the Eleventh Circuit for further consideration in light of Anza v. Ideal Steel Supply Corp., ante, p. ___.
It is so ordered.
|Decision below: Williams v. Mohawk Industries (11th Cir 06/090/2005)||
Williams and other hourly employees alleged that the employer's widespread and knowing employment and harboring of illegal workers allowed the employer to depress wages for its legal hourly employees and to discourage workers compensation claims - all in violation of the federal RICO statute. The trial court denied the employer's motion to dismiss; the 11th Circuit affirmed; the US Supreme Court granted certiorari to review the 11th Circuit decision, and then dismissed the writ "as improvidently granted," and remanded to the 11th Circuit for further consideration in light of Anza v. Ideal Steel Supply Corp (US Supreme Court 06/05/2006).
In the Anza case the Supreme Court held that a RICO plaintiff alleging mail fraud must prove that the alleged violation was the proximate cause of the plaintiff's injury, which requires "some direct relation between the injury asserted and the injurious conduct alleged."
In Mohawk, plaintiffs alleged that the employer (a corporation) was part of a separate RICO "enterprise" made up of a combination of the employer plus recruiting agencies, with common purpose of hiring and harboring illegal workers. The key issue during the Supreme Court arguments was whether a corporation can be part of a RICO "association-in-fact" separate "enterprise." The 11th Circuit concluded that the "enterprise" is the association-in-fact between the employer and the third-party recruiters. The Supreme Court sidestepped that issue.
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