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BRIDGE v. PHOENIX BOND & INDEM. CO.
Supreme Court of United States (2008) | 128 S.Ct. 2131; 553 U.S. 639; 170 L.Ed.2d 1012
TL;DR: Competitors in a tax lien auction sued under the RICO Act, alleging a fraudulent scheme deprived them of winnings. The Court held that a civil RICO plaintiff alleging mail fraud does not need to prove they personally relied on the defendant's misrepresentations to establish causation.
Legal Significance: Clarifies that for civil RICO claims based on mail fraud, the proximate cause requirement can be met without first-party reliance. A plaintiff can sue if their injury is a direct result of the defendant's fraudulent misrepresentations made to a third party.