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Erica P. John Fund, Inc. v. Halliburton Co. Case Brief Summary | Law Case Explained

Get more case briefs explained with Quimbee. Quimbee has over 16,300 case briefs (and counting) keyed to 223 casebooks ► https://www.quimbee.com/case-briefs-o... Erica P. John Fund, Inc. v. Halliburton Co. | 131 S. Ct. 2179, 563 U.S. 804 (2011) To state a private cause of action for securities fraud under Section Ten B of the Securities Exchange Act of nineteen thirty four, plaintiffs must plead six elements. First, a material misrepresentation or omission; second, scienter; third, the conduct occurred in connection with the purchase or sale of a security; fourth, the plaintiff wouldn’t have entered into the transaction but for the defendant’s fraud, known as transaction causation or reliance; fifth, the plaintiff suffered an economic loss; and sixth, there was a causal link between the defendant’s fraud and the plaintiff’s economic loss, known as loss causation. In Erica P John Fund versus Halliburton, the United States Supreme Court considered whether plaintiffs needed to prove loss causation to obtain class certification in a private securities fraud action. Halliburton is a publicly traded energy company. In addition, the Erica P John Fund, which we’ll call the E P J Fund, was an investor in Halliburton. In two thousand eight, a group of investors represented by the E P J Fund filed a class action lawsuit against Halliburton in federal district court for securities fraud. Specifically, the investors claimed that Halliburton made fraudulent representations to inflate the company’s stock price. Halliburton moved to dismiss the action, which the court denied. The E P J Fund then sought to have its proposed class certified under the Federal Rules of Civil Procedure, or F R C P. The court found that the E P J Fund met all the general requirements for class certification, that is, numerosity, commonality, typicality, and adequacy of representation. However, in private securities fraud cases, circuit precedent at the time also required plaintiffs to prove loss causation to obtain class certification, which the E P J Fund failed to do. As a result, the court didn’t certify the class. The E P J Fund appealed to the Fifth Circuit, which affirmed. The United States Supreme Court granted cert. Want more details on this case? Get the rule of law, issues, holding and reasonings, and more case facts here: https://www.quimbee.com/cases/erica-p... The Quimbee App features over 16,300 case briefs keyed to 223 casebooks. Try it free for 7 days! ► https://www.quimbee.com/case-briefs-o... Have Questions about this Case? Submit your questions and get answers from a real attorney here: https://www.quimbee.com/cases/erica-p... Did we just become best friends? Stay connected to Quimbee here: Subscribe to our YouTube Channel ► https://www.youtube.com/subscription_... Quimbee Case Brief App ► https://www.quimbee.com/case-briefs-o... Facebook ►   / quimbeedotcom   Twitter ►   / quimbeedotcom   #casebriefs #lawcases #casesummaries