ED Pennsylvania Dismisses Breach of Contract Case Alleging RESPA and RICO

The Eastern District of Pennsylvania recently dismissed claims that a defendant-title insurer committed violations of RESPA as well as the civil RICO statute stemming from an October 2020 real estate transaction.   

According to the Court, the individual plaintiffs’ actual claim constitutes a $2,000.00 breach of contract connected with a closing fee that was not handled by the title insurer.  Plaintiffs’ complaint alleged 12 counts including the alleged RESPA and RICO violations.

The Court concluded that this extensive complaint was an effort by plaintiffs to “transform a simple contractual dispute into a highly speculative conspiracy.”  Because the Court concluded the value of the case to be $2,000.00 – rather than the “over $75,000.00 in damages for diversity jurisdiction, most of which [came] in the form of unreasonably high attorneys’ fees” – the Court now lacked jurisdiction over what it reasoned to be a simple state law breach of contract case.