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Case Digest on Yegiazaryan v. Smagin

Case Digest on Yegiazaryan v. Smagin
This case clarifies that determining whether a plaintiff has alleged a domestic injury for RICO purposes is context-specific, depending on the facts alleged in the complaint, particularly where the injury and the racketeering activity that caused it occurred.


The case addresses the complexities of assessing domestic injury in civil RICO suits, especially when it involves international parties and activities.

Facts of the Case:

Vitaly Smagin, a Russian resident, won a multimillion-dollar arbitration award against Ashot Yegiazaryan, a California resident, due to investment fund misappropriation. Smagin's efforts to collect the judgment were allegedly thwarted by Yegiazaryan's racketeering activities, leading to a RICO suit.

Issue of the Case:

The Supreme Court examined whether Smagin's inability to collect a California judgment, due to alleged racketeering activities, constitutes a domestic injury under RICO.

Ruling of the Case:

The Court affirmed that the domestic injury inquiry for RICO purposes is context-specific, focusing on the nature of the injury and the racketeering activities that caused it, particularly their location and targets.

This ruling emphasizes the importance of examining the specific facts of each case to determine the presence of a domestic injury under RICO, potentially affecting future litigation involving international elements.


YEGIAZARYAN v. SMAGIN sets a precedent for a nuanced approach to assessing domestic injuries in RICO cases, highlighting the significance of contextual analysis in legal determinations involving complex, cross-border issues.