The Fifth Circuit Court of Appeals reversed and remanded a district court’s dismissal of an insurer’s RICO and fraud-based causes of action alleged against emergency care providers for fraudulent billing, holding that fraud need not be a predicate offense for RICO claims where mail fraud is alleged, that mail fraud is not predicated on reliance, that the insurer did sufficiently plead common law fraud under FRCP 9(b), and that the insurer sufficiently pleaded proximate and but-for causation.
