Simpson, et al. v. Sanderson Farms, Inc., et al., No. 13-10624 (11th Cir. 2014)
Annotate this CasePlaintiffs filed a putative class action under the Racketeer Influenced and Corrupt Organizations Act (RICO), 18 U.S.C. 1961-68, alleging, inter alia, that Sanderson payed depressed wages to all genuinely work-authorized employees at its chicken processing plant. The court concluded that plaintiffs have failed to plausibly establish two of the elements of a civil RICO cause of action - that they suffered an injury in the form of wage depression, or that, even if the court were to assume that they had plausibly shown injury and but-for cause, their injury was directly and proximately caused by Sanderson's pattern of 18 U.S.C. 1546 violations. Accordingly, the court affirmed the judgment of the district court.
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