Devon Drive Lionville, LP, et al. v. Parke Bank, et al.

Petitioners in this case allege that their bank defrauded them out of millions of dollars and committing numerous predicate acts of mail and wire fraud to the FDIC, which the bank did to protect itself from suffering the consequences of having its criminal enterprise discovered. The Third Circuit held that Petitioners were too far removed for purposes of proximate cause to recover against the bank under RICO. The question presented is: What standards and criteria are appropriate in a civil RICO case to determine whether proximate cause exists for a plaintiff who is not the direct recipient of the mail or wire fraud, and therefore is not within the “first step” of the chain causation?