The U.S. Court of Appeals for the Sixth Circuit affirmed on August 11 the dismissal of a high-profile RICO suit brought by General Motors against Fiat Chrysler Automobiles. Seeking billions of dollars in damages, GM alleged that it was harmed when FCA and several of its former executives made improper payments to former United Auto Workers officials.
In 2020, the district court granted FCA’s motion to dismiss, holding that, even accepting GM’s allegations as true, FCA’s conduct did not proximately cause GM’s alleged injury. The district court also denied GM’s request to amend its complaint, finding that GM’s “new” allegations—that certain offshore bank accounts showed that former executives were paid by FCA to spy on GM—were implausible. GM appealed both decisions.
The Sixth Circuit held that the district court correctly rejected GM’s claims of injury because it did not show a direct chain of causation between FCA’s alleged actions and GM’s alleged injuries. The court also determined that GM’s purported new evidence was speculative and did not support its claim that FCA conspired with the UAW to harm GM.
The S&C team includes Matt Porpora, Rick Pepperman, Samantha Hynes, Jacob Cohen and former partner Steven Holley. Matt, Rick and Steve were named runners-up for The American Lawyer’s “Litigator of the Week” for this result.