Anza v. Ideal Steel Supply Corporation, 547 U.S. 451 (2006), was a United States Supreme Court case in which the Court, relying on Holmes v. Securities Investor Protection Corporation, held that to establish standing under the civil Racketeer Influenced and Corrupt Organizations Act (RICO) provision that creates a civil cause of action for any person or entity injured in their business or property by reason of a RICO violation, a plaintiff must demonstrate that he or she was the direct victim of the defendant's RICO violation (e.g., a business may not sue a competitor that may have gained a competitive advantage by not paying taxes).

[3] This civil cause of action provides a private party the means to recover treble damages plus attorney's fees.

Both parties sell steel mill products along with related supplies and services in the New York boroughs of Queens and the Bronx.

[6] Ideal claimed that National engaged in a "pattern of racketeering activity" because the fraudulent returns were submitted on an ongoing and regular basis.

"[12] In [13] the Securities Investor Protection Corporation (SIPC)[14] claimed that Petitioner Robert Holmes conspired with others to manipulate stock prices.

The Court looked to legislative history to interpret section 1964(c)'s provision of a civil cause of action for people injured "by reason of" a defendant's RICO violation.

"When a court evaluates a RICO claim for proximate causation, the central question it must ask is whether the alleged violation led directly to the plaintiff's injuries.

Based on the foregoing reasons, the Court reversed the Second Circuit's holding that Ideal had satisfied the proximate cause requirement under its section 1962(c) claim.

[21] The Court ultimately did not address the question posed in the grant of certiorari: whether a company seeking damages under RICO for alleged mail or wire fraud must prove that it directly relied on the fraudulent conduct, and that this reliance resulted in injury.

While he supported limiting the use of the civil provision of RICO, he felt that the majority's strict proximate causation requirement eliminated recovery for plaintiffs whose injuries are exactly those that Congress intended to remedy.

However, for Justice Breyer, RICO does not provide a private right of action based upon harm induced by normal business practices, such as offering lower prices.

[29] The Court's decision in Ideal apparently does so by imposing a higher burden on plaintiffs to establish a direct link between their injury and the defendant's alleged racketeering activity.

On December 12, 2005, the Supreme Court granted certiorari in Mohawk Industries, Inc. v. Williams,[33] another civil suit brought under section 1964(c) of RICO.

[35] The larger job pool enabled Mohawk to lower the wages of its legal employees and thereby reduce its labor costs.