In In re: McNulty, No. 10-3201, the Sixth Circuit addressed the issue of whether plaintiff was a victim for the purposes of the Crime Victims' Rights Act, involving proceedings where defendant was charged with violating 15 U.S.C. section 1 by participating in a conspiracy to suppress and eliminate competition related to sales of packaged ice in certain areas.
As stated in the decision: "the alleged harm to McNulty stemmed from his firing for refusing to participate in the conspiracy and his 'blackballing' from employment with packaged-ice companies until he stopped working with the government in exposing the conspiracy. If proven, these would indeed be harms to McNulty, but they are not criminal in nature, nor is there any evidence that they are normally associated with the crime of antitrust conspiracy.
Thus, in affirming district court's dismissal, and denying plaintiff's petition for a writ of mandate, the court held that plaintiff is not a victim for purposes of the CVRA.