In the case of Robert A. Beck, II v. Ronald M. Prupis et al., 1999, the U.S Supreme Court ruled that a plaintiff cannot bring a civil conspiracy claim under RICO (Racketeer Influenced and Corrupt Organizations Act) unless he has been injured in his business or property by an act that is independently actionable under RICO. The case involved Robert Beck who was ousted from his position as president of Telematics International Inc., after which he sued several directors alleging they conspired to fraudulently remove him from office and cover up their illegal activities related to company finances. However, the court found that since ousting someone from office does not constitute racketeering activity as defined by RICO, it could not be considered an independent action warranting damages under this law.

In the dissenting opinion for Robert A. Beck, II v. Ronald M. Prupis et al., Justice Stevens argued that the majority's interpretation of Section 10(b) was too narrow and failed to consider Congress' intent in enacting it - to prevent deceptive practices in securities trading. He contended that a broader reading would better serve this purpose by allowing victims of conspiracy to defraud investors an avenue for redress even if they were not directly harmed by any specific act within the scheme itself but rather from being expelled from it, as was Mr.Beck’s case when he tried to stop illegal activities within his firm and got fired instead. Justice Stevens also criticized the majority's reliance on antitrust law precedents which he believed were irrelevant because securities laws are fundamentally different in their objectives and mechanisms than antitrust laws; hence should be interpreted differently. He concluded with expressing concern over how limiting such claims could potentially encourage fraudulent schemes while discouraging whistleblowers like Beck who try to expose them, thus undermining investor confidence and market integrity – contrary to what Congress intended when passing Section 10(b).