Ryder v. Hyles

Dist. Ct. did not err in dismissing for failure to state valid cause of action plaintiffs’ RICO action against defendants-Church, College and Church leader, alleging that defendant-Church leader sexually harassed them in late 1970s, and that defendant-College conspired with other defendants to cover up said sexual abuse. Dist. Ct. could properly dismiss complaint, where plaintiffs had not alleged injury to their business or property as required for RICO civil actions. Moreover, although plaintiffs asserted that they satisfied injury-to-business or property requirement by alleging that defendants used plaintiffs’ fees and donations to fund sham investigation into their claims of sexual abuse, plaintiffs failed to plead connection between fees paid in 1970s and investigation that took place thirty years later. Also, fact that plaintiffs alleged some pecuniary consequences arising out of sexual abuse, said consequences did not qualify as business or property damages.