Commercial Cleaning Services, L.L.C. v. Colin Service Systems, Inc.
United States Court of Appeals for the Second Circuit
271 F.3d 374 (2001)
Commercial Cleaning Services, LLC (Commercial) (plaintiff) was a small company that provided janitorial services for commercial buildings in the Hartford, Connecticut, area. Colin Service Systems, Inc. (Colin) (defendant), a large company, provided office-cleaning services along the eastern seaboard. Commercial was performing successfully on a contract for a company but was underbid by Colin for contracts at the company’s other facilities. Commercial filed a class-action lawsuit on behalf of Colin’s competitors (plaintiffs) alleging that Colin injured competitor firms by hiring undocumented workers at low wages without paying federal and state payroll taxes or workers’ compensation insurance fees in violation of the Racketeer Influenced and Corrupt Organizations Act (RICO). The alleged RICO predicate acts were violations of the Immigration and Nationality Act provision that prohibits hiring undocumented aliens. Colin moved to dismiss the complaint, claiming that Commercial lacked standing. The district court granted Colin’s motion, finding that the complaint did not allege a direct injury proximately caused by Colin’s hiring scheme. Commercial appealed.
Rule of Law
Holding and Reasoning (Leval, J.)
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