In Simpson v. Sanderson Farms, Inc., Case No. 13-10624 (decided March 7, 2014), the United States Court of Appeals for the Eleventh Circuit affirmed the dismissal of a putative class action filed under the Racketeer Influenced and Corrupt Organizations (RICO) Act. The plaintiffs alleged that the defendants’ practice of hiring illegal immigrants had depressed the wages of employees who were lawfully in the country. For practitioners, the larger significance of this Simpson decision lies in the Eleventh Circuit’s enforcing of a high standard for pleading the factual basis for a claim. In Bell Atlantic Corp. v. Twombly, 550 U.S. 544… Read more