## Facts

- Crown Life Insurance Company used Malley-Duff & Associates, Inc. as an insurance agency in the Pittsburgh area.
- Crown Life terminated Malley-Duff’s agency relationship on February 13, 1978, citing failure to meet a production quota.
- Malley-Duff alleged the quota rationale was pretextual and that Crown Life, certain employees, and Agency Holding Corporation formed an enterprise to acquire profitable agencies through fraud, including by imposing an unattainable quota and then terminating the agency.
- In April 1978, Malley-Duff filed a federal antitrust and related state-law action arising from the termination.
- On March 20, 1981, Malley-Duff filed a second action asserting (among other claims) a civil RICO claim under 18 U.S.C. § 1964; only the civil RICO limitations question was at issue.

## Issues

1. What statute of limitations governs a private civil action under RICO, 18 U.S.C. § 1964, when Congress provided none.
2. Whether courts should borrow a state limitations period (such as fraud or a residual “catchall” period) or adopt a uniform federal limitations period, and if federal, which one.

## Decision

- The Court held that civil RICO actions are governed by a uniform federal four-year statute of limitations.
- The Court adopted the four-year period applicable to Clayton Act private civil enforcement actions, 15 U.S.C. § 15b.
- The Court reversed the court of appeals’ use of a state six-year residual limitations period.

## Legal Principles

- When Congress creates a federal cause of action without an express limitations period, courts may borrow a limitations period, including from an analogous federal statute when doing so better serves federal interests.
- Civil RICO claims under 18 U.S.C. § 1964 are subject to a uniform four-year limitations period borrowed from the Clayton Act, 15 U.S.C. § 15b.
- A uniform federal period is preferred for civil RICO because RICO’s predicate acts are diverse, RICO concepts do not map cleanly onto common-law categories, and reliance on varying state periods would create uncertainty, encourage forum shopping, and generate collateral litigation over limitations.
- The Clayton Act is the closest federal analogue to civil RICO because Congress modeled RICO’s private enforcement mechanism on antitrust remedies (including treble damages and attorney’s fees), reflecting a similar balance between deterrence and repose.
- The general five-year federal criminal limitations period does not control civil RICO claims because it reflects criminal enforcement considerations rather than the equities specific to private civil remedies.

## Conclusion

The Court established that all private civil RICO actions are governed by a single, nationwide four-year statute of limitations, borrowed from the Clayton Act, rejecting reliance on varying state limitations periods for RICO claims.


Agency Holding Corp. v. Malley-Duff & Assocs., Inc., 483 U.S. 143 (1987)