What's Left of 'Amgen' After 'Halliburton II'?

When the U.S. Supreme Court issued its anxiously awaited decision in Halliburton. v. Erica P. John Fund (a.k.a., Halliburton II), it answered the most critical issue concerning the future of securities fraud class actions: namely, whether they have a future. They do because the court reaffirmed the fraud on the market presumption of reliance that enables securities fraud actions to proceed as class actions. But the decision also left securities litigators on both sides of the bar wondering where the decision left the Court’s major ruling on class certification in securities actions that came down just last year: Amgen v. Connecticut Ret. Plans & Trust Funds, 133 S. Ct. 1184 (2013).

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