Procedural History
568 U.S. 455 (2013)
The U.S. Supreme Court ruled on the requirements for class certification under the Securities Exchange Act, clarifying the standard for establishing the reliability of market efficiency.
Source: 568 U.S. 455 (2013)
Action: Connecticut Retirement Plans and Trust Funds filed a class action lawsuit against Amgen, alleging securities fraud.
Outcome: The District Court granted Amgen's motion to dismiss, which was later appealed.
Significance: This initial ruling focused on whether the plaintiffs met the requirements for class certification.
Action: The Ninth Circuit reversed the District Court's decision, allowing the case to proceed as a class action.
Outcome: The appellate court determined that plaintiffs could establish reliance on the market for class certification without a need for individualized proof.
Significance: This ruling emphasized the presumption of reliance on the integrity of the market under the fraud-on-the-market theory.
Action: The Supreme Court granted certiorari to review the Ninth Circuit's decision.
Outcome: The Supreme Court upheld the Ninth Circuit's ruling regarding class certification.
Significance: The Supreme Court provided clarity on the requirements for establishing market efficiency and presumption of reliance.
Action: The Supreme Court issued its opinion in Amgen Inc. v. Connecticut Retirement Plans and Trust Funds.
Outcome: The Court confirmed that plaintiffs are not required to prove materiality at the class certification stage.
Significance: This landmark decision reinforced the principles of class action litigation in securities fraud cases.
When the Supreme Court heard the case, it involved an appeal from the Ninth Circuit, which had allowed a class action lawsuit to proceed based on a presumption of reliance due to market efficiency, a key point contested by Amgen.
The Supreme Court applied a de novo standard of review concerning the interpretation of class certification requirements.
The Supreme Court affirmed the Ninth Circuit's decision, allowing the class action to proceed.