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
Argued November 28, 2017
Decided March 20, 2018
Full case nameCyan, Inc. v. Beaver County Employees Retirement Fund
Citations583 U.S. ___ (more)
138 S. Ct. 1061; 200 L. Ed. 2d 332
Case history
PriorCert. 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
Chief Justice
John Roberts
Associate Justices
Anthony Kennedy · Clarence Thomas
Ruth Bader Ginsburg · Stephen Breyer
Samuel Alito · Sonia Sotomayor
Elena Kagan · Neil Gorsuch

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

  1. Cyan, Inc. v. Beaver County Employees Retirement Fund, No. 15-1439, 583 U.S. ___ (2018).
  2. "Champagne for the Plaintiffs' Bar; Dirge Music for the Rest of Us: IPOs, 1933 Act Litigation and the Cyan Decision". Retrieved 28 March 2018.
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