Anza v. Ideal Steel Supply Corp.

How later courts described this case

• holding that plaintiffs failed to adequately allege a causal connection between reduced market prices and defendant's fraudulent activity because prices could be lowered "for any number of reasons unconnected to the asserted pattern of fraud," such as "a cash inflow from some other source or [its conclusion] that the additional sales would justify a smaller profit margin;" the "lowering of prices in no sense required [defendant] to defraud the state tax authority"
• holding that proximate cause did not exist because the harm and violation were not sufficiently related and explaining that the defendant "could have lowered its prices for any number of reasons unconnected to the asserted pattern of fraud,” that the defendant's "lowering of prices in no sense required it to defraud the state tax authority” and "that a company commits tax fraud does not mean the company will lower its prices”
• finding discontinuity between the RICO violation and the asserted injury, explaining that the plaintiff’s “lost sales could have resulted from factors other than the [defendant’s] alleged acts of fraud” and that “[b]usinesses lose and gain customers for many reasons, and it would require a complex assessment to establish what portion of [the plaintiff’s] lost sales were the product of [the defendant’s] decreased prices”
• holding that in evaluating whether the proximate causation element established in Holmes is met, “the central question [a court] must ask is whether the alleged violation led directly to the 5 plaintiff’s injuries,” and declining to “broaden the universe of actionable harms to permit RICO suits by parties who have been injured only indirectly”

Written by the judges who cited it.