BCS Services, Inc. v. Heartwood 88, LLC

Dist. Ct. erred in granting defendants' motion for summary judgment in RICO action alleging that defendants improperly violated local rule prohibiting potential bidders of tax liens to use more than one agent to obtain tax liens where Dist. Ct.'s ruling was based on determination that plaintiffs could not establish that defendants' alleged conduct was proximate cause of plaintiffs losing any tax liens. While record showed possibility that other factors outside of sheer number of bidders in auction room could play role in obtaining winning bids, Dist. Ct. improperly placed burden on plaintiffs to prove nonexistence of potential superceding causes. Moreover, plaintiffs were entitled to trial on their claims where local rule was created for benefit of unrelated bidders, and where plaintiffs' evidence suggested that defendants took business opportunities away by flooding auction room with bidders that should not have been there.