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    UNITED STATES COURT OF APPEALS

    FOR THE NINTH CIRCUIT

    ASSOCIATION OF WASHINGTON
    PUBLIC HOSPITAL DISTRICTS, a
    Washington unincorporated
    association; ADAMS COUNTY PUBLIC
    HOSPITAL DISTRICT NO. 2; ADAMS
    COUNTY PUBLIC HOSPITAL DISTRICT
    NO. 3; AFFILIATED HEALTH
    SERVICES, a general partnership of
    Skagit County Public Hospital
    District No. 1 and Skagit &

    Whatcom Counties Public Hospital
    District No. 304; CHELAN COUNTY
    PUBLIC HOSPITAL DISTRICT NO. 2;
    CLALLAM COUNTY PUBLIC HOSPITAL
                                                         No. 00-35117
    DISTRICT NO. 1; CLALLAM COUNTY
    PUBLIC HOSPITAL DISTRICT NO. 2;                       D.C. No.
    DOUGLAS, GRANT, LINCOLN,                              CV-98-01675-TSZ
    OKANOGAN COUNTIES PUBLIC
                                                         OPINION
    HOSPITAL DISTRICT NO. 6; FERRY
    COUNTY PUBLIC HOSPITAL DISTRICT
    NO. 1, GARFIELD COUNTY PUBLIC
    HOSPITAL DISTRICT; GRANT COUNTY
    PUBLIC HOSPITAL DISTRICT NO. 1;
    GRANT COUNTY PUBLIC HOSPITAL
    DISTRICT NO. 2; GRANT COUNTY
    PUBLIC HOSPITAL DISTRICT NO. 3;
    GRAYS HARBOR COUNTY PUBLIC
    HOSPITAL DISTRICT NO. 1;
    JEFFERSON COUNTY PUBLIC HOSPITAL
    DISTRICT NO. 2; KENNEWICK PUBLIC
    HOSPITAL DISTRICT; KING COUNTY
    PUBLIC HOSPITAL DISTRICT NO. 1;

                                   2375
    KING COUNTY PUBLIC HOSPITAL
    DISTRICT NO. 2; KITTITAS COUNTY
    PUBLIC HOSPITAL DISTRICT NO. 1;
    LEWIS COUNTY PUBLIC HOSPITAL
    DISTRICT NO. 1; MASON COUNTY
    PUBLIC HOSPITAL DISTRICT NO. 1;
    OKANOGAN AND DOUGLAS COUNTIES
    PUBLIC HOSPITAL DISTRICT NO. 1;
    OKANOGAN COUNTY PUBLIC
    HOSPITAL DISTRICT NO. 3;
    OKANOGAN COUNTY PUBLIC
    HOSPITAL DISTRICT NO. 4; PACIFIC
    COUNTY PUBLIC HOSPITAL DISTRICT
    NO. 2; PACIFIC COUNTY PUBLIC
    HOSPITAL DISTRICT NO. 3; PEND
    OREILLE COUNTY PUBLIC HOSPITAL
    DISTRICT NO. 1; PROSSER PUBLIC
    HOSPITAL DISTRICT; SKAGIT COUNTY
    PUBLIC HOSPITAL DISTRICT NO. 1;
    SKAGIT COUNTY PUBLIC HOSPITAL
    DISTRICT NO. 2; SKAGIT  AND
    WHATCOM COUNTIES PUBLIC
    HOSPITAL DISTRICT NO. 304;
    SNOHOMISH COUNTY PUBLIC
    HOSPITAL DISTRICT NO. 1;
    SNOHOMISH COUNTY PUBLIC
    HOSPITAL DISTRICT NO. 2;
    SNOHOMISH COUNTY PUBLIC
    HOSPITAL DISTRICT NO. 3; WHITMAN
    COUNTY PUBLIC HOSPITAL DISTRICT
    NO. 1-A; WHITMAN COUNTY PUBLIC
    HOSPITAL DISTRICT NO. 3,
    Plaintiffs-Appellants,

    v.

                                   2376
    PHILIP MORRIS INCORPORATED; RJ
    REYNOLDS TOBACCO COMPANY;
    BROWN & WILLIAMSON TOBACCO
    CORPORATION; BRITISH AMERICAN
    TOBACCO PLC; B.A.T. INDUSTRIES
    PLC; BRITISH AMERICAN TOBACCO
    INVESTEMENTS LIMITED, formerly
    known as British-American
    Tobacco Company Limited;
    LORILLARD TOBACCO COMPANY;
    LIGGETT GROUP, INC.; LIGGETT &

    MYERS, INC.; UNITED STATES
    TOBACCO COMPANY; THE TOBACCO
    INSTITUTE, INC.; THE COUNCIL FOR
    TOBACCO RESEARCH - USA, INC.;
    SMOKELESS TOBACCO COUNCIL, INC.;
    HILL & KNOWLTON, INC.; UNKNOWN
    CORPORATIONS A-Z,
    Defendants-Appellees.

    Appeal from the United States District Court
    for the Western District of Washington
    Thomas S. Zilly, District Judge, Presiding

    Argued and Submitted
    December 14, 2000--San Francisco, California

    Filed February 22, 2001

    Before: Robert Boochever, Diarmuid F. O'Scannlain, and
    A. Wallace Tashima, Circuit Judges.

    Opinion by Judge O'Scannlain

    _________________________________________________________________

                                   2377

    COUNSEL

    Michael K. Vaska (argued), Bradley J. Berg, Steven G. Jones,
    and Chryssa V. Deliganis, Foster Pepper & Shefelman PLLC,
    Seattle, Washington, for the plaintiffs-appellants.

                                   2381
    Herbert M. Wachtell (argued), Wachtell, Lipton, Rosen &

    Katz, New York, New York, and John W. Phillips, Leonard
    J. Feldman, and Judith H. Ramseyer, Heller Ehrman White &

    McAuliffe LLP, Seattle, Washington, for defendant-appellee
    Philip Morris Incorporated; Bradley S. Keller, Byrnes & Kel-
    ler, LLP, Seattle, Washington, and H. Joseph Escher, III and
    Peter J. Busch, Howard Rice Nemerovski Canady Falk &

    Rabkin, San Francisco, California, for defendant-appellee R.J.
    Reynolds Tobacco; John A. Tondini, Byrnes & Keller, LLP,
    Seattle, Washington, and Jeffrey Davidson and Tony L. Rich-
    ardson, Kirkland & Ellis, Los Angeles, California, for
    defendant-appellee Brown & Williamson Tobacco Corp.;
    Christopher W. Tompkins, Betts Patterson & Mines, P.S.,
    Seattle, Washington, and Jeffrey S. Nelson and Tina M.
    Schaefer, Shook, Hardy & Bacon L.L.P., Kansas City, Mis-
    souri, for defendant-appellee Lorillard Tobacco Company;
    Thomas R. Merrick, Bullivant, Houser, Pendergrass & Hoff-
    man, Seattle, Washington, for defendant-appellee British-
    American Tobacco Co., Ltd.; Delber D. Miller and Heidi
    Bateman, Miller Bateman LLP, Seattle, Washington, for
    defendant-appellee United States Tobacco Company; John D.
    Wilson and David M. Jacobi, Wilson Smith Cochran & Dick-
    erson, Seattle, Washington, for defendant-appellee Smokeless
    Tobacco Council, Inc.; James R. Murray and Franklin D. Cor-
    dell, Gordon Murray Tilden, Seattle, Washington, for
    defendant-appellee The Tobacco Institute, Inc.; James H. Jor-
    dan, Jr., Miller, Nash, Wiener, Hager & Carlsen, Seattle,
    Washington, for defendant-appellee The Council for Tobacco
    Research - U.S.A., Inc.; Thomas J. Brewer and Steven T.
    Seward, Wickwire, Green, Crosby, Brewer & Seward, Seattle,
    Washington, for defendant-appellee Hill & Knowlton, Inc.

    _________________________________________________________________

    OPINION

    O'SCANNLAIN, Circuit Judge:

    We must decide whether public hospital districts may bring
    federal and state claims against tobacco firms to recover their

                                   2382
    unreimbursed costs for treating patients suffering from
    tobacco-related illnesses.

    I

    The Association of Washington Public Hospital Districts,
    along with the Association's individual member districts (col-
    lectively, "Hospital Districts"), appeal from the district
    court's dismissal of their federal antitrust, Racketeer Influ-
    enced and Corrupt Organizations Act ("RICO"), and supple-
    mental state law claims against a number of tobacco
    companies and tobacco industry organizations (collectively,
    "Tobacco Firms"). The Hospital Districts are political subdi-
    visions of the State of Washington which are required by state
    and federal law to provide health care services to the general
    public regardless of their patients' ability to pay.

    The Hospital Districts allege that the Tobacco Firms have
    engaged in a half-century conspiracy against the public gener-
    ally and the health care industry in particular. According to
    the Hospital Districts, the Tobacco Firms have conspired to
    misrepresent and to conceal the addictive nature of nicotine
    and the health risks associated with tobacco use, promoting
    their alleged deception through propaganda disguised as inde-
    pendent scientific research while endeavoring to suppress
    legitimate scientific research that demonstrates the dangers of
    tobacco use. The Hospital Districts further claim that the
    Tobacco Firms have conspired to suppress competition to
    develop less harmful nicotine and tobacco products and have
    manipulated the levels of nicotine in their products to ensure
    continuing addiction. Finally, the Tobacco Firms have alleg-
    edly conspired to refrain from making any claims concerning
    the relative health superiority of specific tobacco products.

    According to the Hospital Districts, the Tobacco Firms'
    unlawful conduct has caused them considerable financial
    harm. But for the Tobacco Firms' conspiracy to suppress
    competition, they allege, less harmful tobacco products would

                                   2383
    have been developed which would have garnered a substantial
    market share. The Hospital Districts maintain that they them-
    selves were potential consumers of such products, as they
    could have purchased them for the use and treatment of their
    patients suffering from nicotine addiction. Patients who used
    these less harmful products presumably would have experi-
    enced fewer tobacco-related health illnesses, thereby reducing
    the Hospital Districts' costs for treating such illnesses. Fur-
    ther, the Tobacco Firms' alleged conspiracy to spread misin-
    formation regarding the adverse health effects of tobacco use,
    the addictive nature of nicotine, and the Tobacco Firms' own
    manipulation of nicotine levels allegedly prevented the Hospi-
    tal Districts from instituting more effective smoking cessation
    programs. Such misinformation also induced the Hospital
    Districts' patients to use tobacco products. Thus, but for the
    Tobacco Firms' alleged conspiracy to deceive the public, the
    Hospital Districts could have assisted more patients to over-
    come their addiction to nicotine products, again reducing their
    costs for treating tobacco-related illnesses.

    The Hospital Districts commenced this action against the
    Tobacco Firms to recover their increased costs for treating
    their patients' tobacco-related illnesses caused by the Tobacco
    Firms' unlawful conduct, alleging federal antitrust and RICO
    violations; state common law claims for fraudulent misrepre-
    sentation, fraudulent concealment, breach of special duty,
    unjust enrichment, civil conspiracy, and public nuisance; and
    violations of the Washington Unfair Business Practices Act--
    Consumer Protection Act, Wash. Rev. Code Ann.
    SS 19.86.020-030. In a carefully reasoned decision, the dis-
    trict court dismissed all claims with prejudice for failure to
    state a claim, relying on Oregon Laborers-Employers Health
    & Welfare Trust Fund v. Philip Morris Inc., 185 F.3d 957
    (9th Cir. 1999). The court held that the Hospital Districts did
    not have antitrust or RICO standing because their claimed
    damages were not proximately caused by the Tobacco Firms'
    unlawful conduct, but were instead derivative of the personal
    injuries of smokers afflicted by tobacco-related illnesses.

                                   2384
    Ass'n of Wash. Pub. Hosp. Dists. v. Philip Morris, Inc., 79 F.
    Supp. 2d 1219, 1224 (W.D. Wash. 1999). The court also held
    that the Hospital Districts' antitrust claims were barred for
    lack of antitrust injury under Am. Ad Mgmt Inc. v. GTE of
    Cal., 190 F.3d 1051, 1057 (9th Cir. 2000), because the Hospi-
    tal Districts did not experience their injuries in the market
    where competition was being restrained. Ass'n of Wash. Pub.
    Hosp. Dists., 79 F. Supp. 2d at 1226. Finally, the district court
    dismissed the Hospital Districts' state common law claims for
    lack of proximate cause, id. at 1228-29, and dismissed their
    Consumer Protection Act claims under Wash. State Physi-
    cians Ins. Exch. & Ass'n. v. Fisons Corp., 858 P.2d 1054,
    1060-61 (Wash. 1993), for failure to allege an injury to "busi-
    ness or property," Ass'n of Wash. Pub. Hosp. Dists., 79 F.
    Supp. 2d at 1229. This appeal followed.

    II

    We must first decide whether the district court erred in dis-
    missing the Hospital Districts' federal antitrust and RICO
    claims.

    A

    [1] Section 4 of the Clayton Act provides that "any person
    who shall be injured in his business or property by reason of
    anything forbidden in the antitrust laws" may bring a private
    damages suit. 15 U.S.C. S 15. Similarly, 18 U.S.C. S 1964(c)
    provides that "[a]ny person injured in his business or property
    by reason of a violation of section 1962," the substantive pro-
    visions of RICO, may bring a private damages suit. 18 U.S.C.
    S 1964(c). Nonetheless, the courts have recognized that pri-
    vate antitrust and RICO actions are subject to traditional "ju-
    dicial tools to limit a person's responsibility for the
    consequences of that person's own acts." Holmes v. Sec.
    Investor Prot. Corp., 503 U.S. 258, 268 (1992). Among these
    limitations is the requirement that the alleged violations of the
    law be the "proximate cause" of the injury suffered. Id.

                                   2385
    (RICO); Blue Shield v. McCready, 457 U.S. 465, 477 (1982)
    (antitrust).

    [2] A direct relationship between the injury and the alleged
    wrongdoing has been one of the "central elements " of the
    proximate causation determination, and "a plaintiff who com-
    plained of harm flowing merely from the misfortunes visited
    upon a third person by the defendant's acts [  ] generally [has
    been] said to stand at too remote a distance to recover." Ore-
    gon Laborers, 185 F.3d at 963 (quoting Holmes, 503 U.S. at
    268-69 (internal citations omitted)). To determine whether an
    injury is "too remote" to allow recovery under both the anti-
    trust laws and RICO, a three-factor test is applied:"(1)
    whether there are more direct victims of the alleged wrongful
    conduct who can be counted on to vindicate the law as private
    attorneys general; (2) whether it will be difficult to ascertain
    the amount of the plaintiff's damages attributable to defen-
    dant's wrongful conduct; and (3) whether the courts will have
    to adopt complicated rules apportioning damages to obviate
    the risk of multiple recoveries." Id. (citing Holmes, 503 U.S.
    at 269-70, and Associated Gen. Contractors of Cal., Inc. v.
    Cal. State Council of Carpenters ("AGC "), 459 U.S. 519, 545
    (1983)).

    In Oregon Laborers, we considered the antitrust and RICO
    proximate cause requirement in the tobacco litigation context.
    There, five union health and welfare trust funds that provide
    health care benefits to their beneficiaries brought suit against
    various tobacco firms, alleging federal antitrust and RICO
    violations as well as state common law and statutory claims.
    The trusts' complaint was predicated on the same conspiracy
    allegations as are at issue here. Id. at 961. Like the Hospital
    Districts, the trusts sought to recover their increased expendi-
    tures for treatment of their beneficiaries' tobacco-related ill-
    nesses that allegedly resulted from the tobacco defendants'
    wrongdoing. Id. at 962.

    We held that the trusts' claims failed as a matter of law. We
    explained that the trusts lacked both antitrust and RICO stand-

                                   2386
    ing, as they could not establish that their injuries were proxi-
    mately caused by the tobacco defendants' wrongdoing. Id. at
    963-66. We observed that the trusts' injuries were entirely
    derivative in nature, for "without any injury to smokers, plain-
    tiffs would not have incurred the additional expenses in pay-
    ing for the medical expenses of those smokers." Id. at 963.
    Thus, there was no "direct link" between the defendants'
    alleged wrongdoing and the trusts' damages, and the proxi-
    mate cause requirement was not met. Id. at 964.

    We then applied the three-factor AGC/Holmes proximate
    cause test. We held that the first factor weighed against the
    trusts because there existed more directly injured victims, in
    the form of the smokers themselves, who would be motivated
    to punish the defendants for their wrongdoing. Id. We recog-
    nized that such directly injured victims could not bring suit
    under RICO or the antitrust laws, given that they suffered per-
    sonal injuries rather than the requisite "injury to business or
    property." Id. Nonetheless, we rejected the trusts' argument
    that this weighed in favor of standing. Although smokers
    could not vindicate the public interest in antitrust enforce-
    ment, they could bring other claims to deter the defendants'
    wrongdoing. Id. Next, we observed that the trusts' damages
    were entirely speculative in nature, as they would involve
    proof, ultimately, of how smokers themselves would have
    changed their behavior in the absence of the defendants'
    wrongdoing. Id. at 965. We remarked that"[t]he difficulty of
    ascertaining the damages attributable to defendants' alleged
    wrongful conduct and the complexity involved in calculating
    these damages weigh heavily, if not dispositively, in favor of
    barring plaintiffs' actions." Id. Finally, we noted that there
    was the potential for duplicative recovery given the possibility
    that smokers might bring suit against the defendants for their
    personal injuries under state law theories. Id.  at 966.

                                   2387
    B

    All other Courts of Appeals that have addressed the issue
    have agreed that union trust funds lack standing to bring anti-
    trust and RICO claims against the tobacco industry to recover
    their increased expenditures for treating tobacco-related ill-
    nesses.1 The fact that the Hospital Districts are health care
    providers rather than third party health care payers like the
    union trusts in Oregon Laborers is immaterial for purposes of
    RICO and antitrust standing. The ratio decidendi  of Oregon
    Laborers and the union health trust cases from our sister cir-
    cuits is fatal to the Hospital Districts' claims.

    [3] Like the union trust funds in Oregon Laborers, the Hos-
    pital Districts are attempting to recover damages that are
    derivative of the injuries suffered by smokers. The district
    court properly noted that "[w]ithout any injury to smokers,
    plaintiffs would not have incurred the additional expenses in
    paying for the medical expenses of those smokers. " Ass'n of
    Wash. Pub. Hosp. Districts, 79 F. Supp. 2d at 1224. Thus,
    there is no direct link between the alleged misconduct of the
    Tobacco Firms and the Hospital Districts' claimed damages.

    [4] As we did in Oregon Laborers , the district court exam-
    ined the Hospital Districts' claims according to the proximate
    cause factors set forth in AGC and Holmes: the directness of
    the injury, the speculative nature of the harm, and the risk of
    duplicative recovery and complexity of apportioning dam-
    ages. Id. at 1224-25. The court correctly concluded that each
    of these factors weighs strongly against according the Hospi-
    tal Districts antitrust and RICO standing. Id.  at 1224-26,
    _________________________________________________________________
    1 See United Food & Commercial Workers v. Philip Morris, Inc., 223
    F.3d 1271 (11th Cir. 2000); Texas Carpenters Health Benefit Fund v.
    Philip Morris, Inc., 199 F.3d 788 (5th Cir. 2000); Int'l Bhd. of Teamsters
    v. Philip Morris, Inc., 196 F.3d 818 (7th Cir. 1999); Steamfitters Local
    Union No. 420 Welfare Fund v. Philip Morris, Inc. , 171 F.3d 912 (3d Cir.
    1999); Laborers Local 17 v. Philip Morris, Inc. , 191 F.3d 229 (2d Cir.
    1999).

                                   2388
    1227. Smokers are the "more direct victims" who can vindi-
    cate the public interest in deterring the Tobacco Firms'
    wrongful conduct. See Oregon Laborers, 185 F.3d at 964.
    The difficulty of ascertaining the Hospital Districts' damages
    attributable to such wrongful conduct is just as great here as
    it was in Oregon Laborers. Calculation of the Hospital Dis-
    tricts' damages would entail considerable speculation regard-
    ing how individuals' tobacco usage would have changed in
    the event that accurate information and less harmful tobacco
    products were available. See id. at 965. Finally, the same
    potential for duplicative recovery is present given the possi-
    bility that smokers themselves could bring state law claims
    against the Tobacco Firms to recover for their personal injuries.2
    See id. at 966.

    C

    The Hospital Districts offer several possible bases on which
    to distinguish Oregon Laborers. The common theme underly-
    ing the Hospital Districts' contentions is that looser RICO and
    antitrust standing rules apply to health providers due to their
    special relationship with their patients, a relationship that
    third party payers such as union health trusts lack. 3 The differ-
    _________________________________________________________________
    2 The Hospital Districts contend that the risk of duplicative recovery
    here is greatly reduced because, under the terms of the Master Settlement
    Agreement between certain states, including Washington, and the tobacco
    industry, any recovery by the Hospital Districts would be offset by a cor-
    responding reduction in Washington's award under the Master Settlement
    Agreement. Assuming, arguendo, that this is accurate, it has no bearing on
    the possibility of duplicative recovery in the event that individual smokers
    who have been patients of the Hospital Districts bring suit against the
    Tobacco Firms. In fact, it was the possibility of claims by injured smokers,
    rather than state governments, that led us in Oregon Laborers to hold that
    the second AGC/Holmes factor weighed in favor of the tobacco defen-
    dants. Oregon Laborers, 185 F.3d at 966.
    3 The Hospital Districts also submit that they should have standing
    because, as political subdivisions of the state, they are possessed of certain
    attributes of sovereignty. Nevertheless, they do not, and in fact could not,

                                   2389
    ences between health care providers and third party payers,
    however, do nothing to remedy the fundamental defect with
    the Hospital Districts' claims: they are attempting to recover
    for harm that is derivative of personal injuries visited upon
    their patients. Their claims are just as remote, and would
    occasion the same unfounded speculation concerning dam-
    ages, as the union trusts' claims in Oregon Laborers. Thus,
    the Hospital Districts' attempts to distinguish Oregon Labor-
    ers are unavailing.

    The Hospital Districts cite McCready, 457 U.S. 465, as
    establishing a special rule of antitrust standing for health care
    providers. The Hospital Districts are incorrect. In McCready,
    a group health plan subscriber brought an antitrust suit against
    the plan, alleging that it conspired with psychiatrists to
    restrain competition in the psychotherapy market. Id. at 467.
    The plan reimbursed its subscribers for psychotherapy treat-
    ment provided by psychiatrists, but not psychologists. The
    plaintiff received unreimbursed treatment from a psycholo-
    gist. Id. While recognizing that the conspiracy was targeted at
    psychologists rather than plan subscribers, the Court neverthe-
    less held that the plaintiff had antitrust standing, explaining
    that "[d]enying reimbursement to subscribers for the cost of
    treatment was the very means by which it is alleged that Blue
    Shield sought to achieve its illegal ends." Id. at 479. The
    Court further explained that the plaintiff's injury "was inextri-
    cably intertwined with the injury the conspirators sought to
    inflict on psychologists . . . ." Id. at 484.

    McCready does not establish a special standing rule for
    health care providers, as the Hospital Districts would read it,
    _________________________________________________________________
    insist that any such quasi-sovereign status exempts them from the proxi-
    mate cause requirement. Allegheny Gen. Hosp. v. Philip Morris, Inc., 228
    F.3d 429, 436 (3d Cir. 2000) (public hospitals cannot invoke quasi-
    governmental standing to sue tobacco companies on behalf of their non-
    paying patients without regard to proximate cause).

                                   2390
    nor does it dispense with the general requirement that antitrust
    and RICO plaintiffs must be directly harmed by the defen-
    dant's wrongful conduct. As the Court subsequently explained
    in AGC, in McCready "the actual plaintiff was directly
    harmed by the defendants' unlawful conduct." AGC, 459 U.S.
    at 529 n.19. She was denied reimbursement for her psycho-
    therapy expenses. Her damages were not derivative of the
    harm the conspirators inflicted upon psychologists. In fact, the
    Court noted that McCready's psychologist was fully paid for
    his services and was in no way injured by Blue Shield's
    refusal to reimburse McCready for the cost of such services.
    McCready, 457 U.S. at 475. Neither McCready  nor any of the
    other cases cited by the Hospital Districts provides any sup-
    port for the Hospital Districts' attempt to recover for their
    remote harm.4

    [5] Similarly, the fact that the Hospital Districts allege that
    they were potential purchasers of less harmful tobacco and
    nicotine delivery products does not render their claims any
    less remote. The harm suffered by the Hospital Districts as
    potential purchasers of products whose development the
    Tobacco Firms allegedly conspired to suppress is derivative
    of the harm suffered by their patients, who were the potential
    users of such products. Had such less harmful products been
    available, the Hospital Districts' patients might have used
    them, and in turn might have suffered from fewer tobacco-
    related diseases, with the result that the Hospital Districts
    might have incurred lower tobacco-related treatment costs.
    This is the very essence of a derivative injury.
    _________________________________________________________________
    4 The Hospital Districts cite several other cases which purportedly rec-
    ognize a special standing rule for health care providers. However, these
    cases concern constitutional standing, not RICO or antitrust standing. See
    NOW v. Scheidler, 510 U.S. 249, 255-56 (1994); Singleton v. Wulff, 428
    U.S. 106, 113-18 (1976); Lee v. Oregon, 869 F. Supp. 1491, 1493-95 (D.
    Or. 1994), vacated on other grounds by 107 F.3d 1382 (9th Cir. 1997).
    Thus, they are inapposite.

                                   2391
    D

    [6] The Hospital Districts' antitrust claims fail on a second,
    independent ground: failure to allege an antitrust injury. An
    "antitrust injury" is an injury of "the type that the antitrust
    statute was intended to forestall." AGC, 459 U.S. at 540. "The
    requirement that the alleged injury be related to anti-
    competitive behavior requires, as a corollary, that the injured
    party be a participant in the same market as the alleged male-
    factors." Bhan v. NME Hosps., Inc., 772 F.2d 1467, 1470 (9th
    Cir. 1985). Further, "[a]ntitrust injury requires the plaintiff to
    have suffered its injury in the market where competition is
    being restrained. Parties whose injuries, though flowing from
    that which makes the defendant's conduct unlawful, are expe-
    rienced in another market do not suffer antitrust injury." Am.
    Ad Mgmt., Inc., 190 F.3d at 1057.

    [7] Although the Hospital Districts allege that they are
    potential participants in the nicotine delivery market, and this
    is the market where competition allegedly has been restrained,
    the district court ruled that they nonetheless failed to state an
    antitrust injury. The court reasoned that the Hospital Districts'
    injuries were not experienced in the nicotine delivery market,
    but rather in the health care market. We agree. The essence
    of the Hospital Districts' allegations is that the Tobacco
    Firms' conspiracy to suppress the development of less harm-
    ful tobacco products indirectly resulted in the Districts' incur-
    ring increased health care expenses. These expenses simply
    cannot be characterized as injuries that the Hospital Districts
    experienced in the nicotine delivery market. See Serv.
    Employees Int'l Union Health & Welfare Fund v. Philip Mor-
    ris Inc., 83 F. Supp. 2d 70, 90 (D.D.C. 1999) (holding that
    plaintiff union health trusts did not suffer an antitrust injury,
    notwithstanding their claim to be potential purchasers of nico-
    tine replacement products, because their asserted "infrastruc-
    ture damages" "are not the type that would result from
    anticompetitive activity in the nicotine products market
    . . . .").

                                   2392
    [8] Accordingly, the district court properly dismissed the
    Hospital Districts' federal RICO and antitrust claims.5

    III

    We must next decide whether the district court properly
    dismissed the Hospital Districts' state law claims.

    A

    [9] The Hospital Districts brought suit against the Tobacco
    Firms under the Washington Consumer Protection Act
    ("CPA"), Wash. Rev. Code Ann. SS 19.86.0206 and 19.86.030.7
    The CPA provides a cause of action to "[a]ny person who is
    injured in his or her business or property by a violation of" the
    substantive provisions of the CPA. Wash. Rev. Code Ann.
    S 19.86.090; Wash. State Physicians Ins. Exch. & Ass'n. v.
    Fisons Corp., 858 P.2d 1054, 1060 (Wash. 1993). Expenses
    for personal injuries are not injuries to business or property
    under the CPA. Id. at 1064.

    [10] The district court held that the Hospital Districts failed
    to meet such "business or property" requirement because their
    claimed injuries were predicated on personal injuries to smok-
    ers. Ass'n of Wash. Pub. Hosp. Dists., 79 F. Supp. 2d at 1229.
    The district court observed that smokers themselves could not
    recover their own smoking-related medical expenses under
    the CPA; accordingly, the mere fact that a third party pays for
    _________________________________________________________________
    5 We note, finally, that while the Hospital Districts, unlike the union
    trusts, apparently cannot avail themselves of a contract-based subrogation
    right to bring suit against the Tobacco Firms, this is irrelevant to the ques-
    tion of whether their antitrust and RICO claims fail for remoteness.
    6 Wash. Rev. Code Ann. S 19.86.020 provides, "[u]nfair methods of
    competition and unfair or deceptive acts or practices in the conduct of any
    trade or commerce are hereby declared unlawful."
    7 Wash. Rev. Code Ann. S provides, "[e]very contract, combination, in
    the form of trust or otherwise, or conspiracy in restraint of trade or com-
    merce is hereby declared unlawful."

                                   2393
    their medical treatment should not transform such medical
    expenses into business or property harm recoverable under the
    CPA. Id.

    We came to the same conclusion in Oregon Laborers,
    where we held that union trusts could not recover their
    expenses incurred to treat tobacco-related illnesses under Ore-
    gon's Unfair Trade Practices Act ("UTPA"), Or. Rev. Stat.
    S 646.638(1). Like the Washington CPA, "any person who
    suffers any ascertainable loss of money or property, real or
    personal, as a result" of the substantive provisions of the
    UTPA has standing to bring suit under the Oregon statute. Or.
    Rev. Stat. S 646.638(1). Again like the Washington CPA, the
    Oregon UTPA does not permit recovery for personal injuries.
    Gross-Haentjens v. Leckenby, 589 P.2d 1209, 1210-11 (Or.
    Ct. App. 1979) ("[W]e hold that ORS 646.638 of the Oregon
    Unlawful Trade Practices Act was not intended by the legisla-
    ture to create such a new cause of action for personal inju-
    ries."). In rejecting the union trusts' claims under the UTPA,
    we observed that "[p]laintiffs' damages--expenses to treat
    smokers' personal injuries--are clearly predicated upon `per-
    sonal injury' and are therefore unrecoverable under the
    UPTA." Oregon Laborers, 185 F.3d at 968. 8

    In light of the similarity between the Washington and Ore-
    gon consumer protection statutes, we hold that Oregon Labor-
    ers bars the Hospital Districts' CPA claim to recover for their
    unreimbursed expenses treating their patients' smoking-
    related illnesses.
    _________________________________________________________________
    8 Nor does Fisons Corp. require a different result. In Fisons Corp., the
    Supreme Court of Washington held that a physician could recover under
    the Washington Consumer Protection Act for damages he suffered result-
    ing from a drug manufacturer's failure to warn him of the known dangers
    of a drug he prescribed to a patient. Fisons Corp., 858 P.2d at 1061. The
    physician in Fisons Corp. did not seek to recover for his expenses incurred
    in treating the patient who was harmed by the drug, but rather sought to
    recover for the injury to his reputation occasioned by the misprescription.
    Id. at 1061, 1063. Fisons Corp. thus provides no support for the Hospital
    Districts.

                                   2394
    [11] The Hospital Districts' CPA claim fails as a matter of
    law for the additional reason that, as discussed above, the
    Tobacco Firms' unlawful conduct was not the proximate
    cause of the Hospital Districts' injuries. Proximate cause is an
    element of a claim under the CPA. Fisons Corp. , 858 P.2d at
    1062. The Washington courts are directed to interpret the
    CPA in light of federal court decisions interpreting federal
    antitrust law. Wash. Rev. Code Ann. S 19.86.920; Fisons
    Corp., 858 P.2d at 1064. Further, "any departure from federal
    law . . . must be for a reason rooted in [Washington] statutes
    or case law and not in general policy arguments that th[e]
    court would weigh if the issue came before [it ] as matter of
    first impression." Blewett v. Abbott Labs. , 938 P.2d 842, 846
    (Wash. Ct. App. 1997), review denied, 950 P.2d 475 (Wash.
    1998). The Hospital Districts have failed to point to any rea-
    son "rooted in state statutes or case law" that would support
    our departure from federal antitrust proximate cause princi-
    ples when analyzing the proximate cause requirement under
    the CPA.

    Accordingly, we affirm the district court's dismissal of the
    Hospital Districts' CPA claim.

    B

    [12] Finally, we must consider whether the district court
    properly dismissed the Hospital Districts' Washington state
    common law claims. Only the Hospital Districts' fraudulent
    concealment, fraudulent misrepresentation, and nuisance
    claims are before us.9 Proximate cause is an element of each
    of these claims under Washington law. Amtruck Factors, Div.
    of Truck Sales, Inc. v. Int'l Forest Prods., 795 P.2d 742, 746
    (Wash. Ct. App. 1990) (observing that proximate cause is an
    essential element of a fraud claim under Washington law);
    _________________________________________________________________
    9 The Hospital Districts have failed to brief the district court's dismissal
    of their unjust enrichment, breach of special duty, and conspiracy claims.
    These claims are thus waived.

                                   2395
    DeYoung v. Cenex Ltd., 1 P.3d 587, 590 (Wash. Ct. App.
    2000) (recognizing that proximate cause is an element of a
    nuisance claim). Washington courts have defined proximate
    cause in a manner consistent with the common law "direct-
    ness" requirement, as a cause "which, in a direct sequence
    unbroken by any new independent cause, produces the injury
    complained of, and without which such injury would not have
    happened." Fisher v. Parkview Props., Inc. , 859 P.2d 77, 82
    (Wash. Ct. App. 1993) (citing Alger v. Mukilteo , 730 P.2d
    1333, 1336 (Wash. 1987); Hartley v. State, 698 P.2d 77, 83
    (Wash. 1985)) (emphasis added).

    [13] The Hospital Districts' common law claims thus fail
    for the same reasons that their federal antitrust and RICO
    claims failed: the Tobacco Firms' unlawful conduct was not
    the proximate cause of their injuries. The proximate cause test
    for federal antitrust and RICO standing is the common law
    proximate cause test. AGC, 459 U.S. at 531; Holmes, 503
    U.S. at 268-69; Laborers Local 17 v. Philip Morris, Inc., 191
    F.3d 229, 234 (2d Cir. 1999) ("To determine in a given case
    whether proximate cause is present [for purposes of RICO
    claims], common law principles are applied."). Accordingly,
    the district court correctly dismissed the Hospital Districts'
    fraudulent concealment, fraudulent misrepresentation and nui-
    sance claims. Oregon Laborers, 185 F.3d at 968 ("[F]or the
    same reasons that proximate cause did not exist for plaintiffs'
    RICO and antitrust claims, proximate cause is lacking for
    their fraud claim"). See also Steamfitters Local Union No. 420
    Welfare Fund v. Philip Morris, Inc., 171 F.3d 912, 934-35 (3d
    Cir. 1999) ("The same principles that lead us to conclude that
    plaintiffs' antitrust and RICO claims were properly dismissed
    lead to the inevitable conclusion that their state law claims
    must also fail . . . . Just as we have found the link between
    defendants' alleged fraud--providing false information
    regarding the safety of their products--and plaintiffs' alleged
    injuries too attenuated to support a RICO claim, we also find
    the link too remote to support a common-law fraud claim.");
    Allegheny Gen. Hosp. v. Philip Morris, Inc., 228 F.3d 429,

                                   2396
    445-46 (3d Cir. 2000) (dismissing state claims based on the
    "same principles that lead us to conclude that plaintiffs' anti-
    trust and RICO claims were properly dismissed": lack of
    proximate cause).

    IV

    For the foregoing reasons, the judgment of the district court
    is

    AFFIRMED.10

    _________________________________________________________________
    10 Defendants-Appellees' Motion to File Appendix of Unpublished
    Opinions is DENIED.
                                   2397

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