Beck v. Prupis

In 1987 certain high-level employees of a construction surety-bond company, Southeastern Insurance Group (SIG), including Ronald Prupis, Leonard Bellezza, William Paulus, Jr., Ernest Sabato, Harry Olstein, Frederick Mezey, and Joseph Littenberg (the senior employees) (defendants) began various racketeering endeavors. In early 1988, Robert Beck II (plaintiff), the CEO and director of SIG, discovered the illegal conduct of the senior employees and contacted regulators. The senior employees devised a plan to remove Beck from the company by hiring a consultant to write a report falsely stating Beck had not performed his material duties. The board then fired Beck. Beck sued the senior employees in federal district court, including a civil claim under 18 U.S.C. § 1964(c), the provision of the Racketeer Influenced and Corrupt Organizations Act (RICO) that establishes a civil cause of action. Beck contended that the senior employees conspired to commit numerous racketeering activities and that his injury was proximately caused by an overt act done in furtherance of the conspiracy. The senior employees filed a motion for summary judgment on the ground that Beck did not have standing to sue under RICO for damages from loss of employment. The district court dismissed Beck’s RICO civil conspiracy claim, and the court of appeals affirmed. The Supreme Court granted certiorari upon appeal.