In the final days of 2020, a district court within the Sixth Circuit became the first in the circuit to rely upon the disputed “co-conspirator exception” to the Supreme Court’s “direct-purchaser rule” for civil RICO lawsuits. The development is significant for future civil RICO plaintiffs: the exception will enable more businesses involved in complex supply or distribution chains to bring civil RICO suits where the direct purchaser rule had previously been a major hurdle.
