Cyan, Inc. v. Beaver County Employees Retirement Fund
Cyan, Inc. v. Beaver County Employees Retirement Fund, 583 U.S. ___ (2018), was a United States Supreme Court case in which the Court held the Securities Litigation Uniform Standards Act of 1998 did not strip state courts of jurisdiction to adjudicate class actions alleging only 1933 Securities Act violations; nor did it authorize removing such suits from state to federal court.[1]
Cyan, Inc. v. Beaver County Employees Retirement Fund | |
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Argued November 28, 2017 Decided March 20, 2018 | |
Full case name | Cyan, Inc. v. Beaver County Employees Retirement Fund |
Citations | 583 U.S. ___ (more) 138 S. Ct. 1061; 200 L. Ed. 2d 332 |
Case history | |
Prior | Cert. granted, 137 S. Ct. 2325 (2017). |
Holding | |
The Securities Litigation Uniform Standards Act of 1998 did not strip state courts of jurisdiction to adjudicate class actions alleging only 1933 Securities Act violations; nor did it authorize removing such suits from state to federal court. | |
Court membership | |
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The Second Circuit (which includes New York) put 1933 Act cases in federal court, while the Ninth Circuit (which includes California) allowed ’33 Act cases in state court. This circuit split was decided in favor of the Ninth Circuit’s interpretation.[2]
References
- Cyan, Inc. v. Beaver County Employees Retirement Fund, No. 15-1439, 583 U.S. ___ (2018).
- "Champagne for the Plaintiffs' Bar; Dirge Music for the Rest of Us: IPOs, 1933 Act Litigation and the Cyan Decision". Retrieved 28 March 2018.
External links
- Text of Cyan, Inc. v. Beaver County Employees Retirement Fund, 583 U.S. ___ (2018) is available from: Justia Oyez (oral argument audio) Supreme Court (slip opinion)
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