Hunt v. Zuffa, LLC

United States District Court, District of Nevada · Torts

TortsRICOFraudBatteryContractUnjust EnrichmentCivil ConspiracyRule 12(b)(6)

Facts

Hunt, a UFC fighter, alleged that UFC, Dana White, and Brock Lesnar manipulated UFC's anti-doping rules to allow selected fighters to use banned substances. He claimed that fights against allegedly doped opponents, especially his loss to Lesnar at UFC 200, caused him financial losses including cancelled appearances, reduced advertising revenue, lower licensing fees, reduced book sales, and physical injury. Hunt also alleged UFC later removed him from a scheduled event in retaliation for filing suit. His contract with UFC provided a fixed purse per bout regardless of win or loss and barred consequential damages.

Issue

Whether Hunt's amended and supplemental complaints plausibly stated claims for federal and Nevada RICO, fraud, aiding and abetting, breach of contract, unjust enrichment, battery, and civil conspiracy. More specifically, the court considered whether Hunt adequately alleged non-speculative, proximately caused damages and otherwise satisfied the substantive elements of those claims.

Rule

To state a civil RICO claim, a plaintiff must allege conduct of an enterprise through a pattern of racketeering activity causing injury to business or property, and must show statutory standing by pleading a qualifying injury and proximate causation. RICO proximate cause requires a direct causal link; speculative, attenuated chains of causation do not suffice, and personal injuries or their economic consequences are not compensable under RICO. Fraud likewise requires that the misrepresentation proximately cause damages; unjust enrichment is unavailable where an existing contract governs the dispute; consent bars battery in sports unless the challenged conduct is totally outside the ordinary activity of the sport; and civil conspiracy requires an agreement to commit a viable underlying tort.

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One of 10 multiple-choice questions for this case. Pick an answer to see why.

During a sanctioned kickboxing bout in Phoenix, Diego Ramos suffered a fractured orbital bone after allegedly facing an opponent who had secretly used banned stimulants. Diego later sued the promoter under civil RICO, seeking recovery for the endorsement income he lost while sidelined during surgery and rehabilitation.

Under the majority's reasoning, does Diego adequately allege a compensable RICO injury?

Explanation. The majority held that personal injuries are not compensable under RICO, and neither are the economic consequences of those injuries. Diego's lost endorsement income stems from his physical injury and recovery period, so it is not a qualifying injury to business or property for civil RICO standing.