Halliburton Co. v. Erica P. John Fund, Inc.
United States Supreme Court
573 U.S. 258 (2014)
The Erica P. John Fund (EPJ Fund) (plaintiff) sued Halliburton (defendant) for securities fraud, alleging misrepresentations about revenue, a merger, and liabilities, and moved to certify a class of all investors who bought Halliburton stock during the relevant period. Halliburton opposed certification with evidence that the alleged misstatements had no actual impact on its stock price, arguing that lack of price impact rebutted the presumption of investor reliance established in a prior landmark securities case; EPJ Fund argued such rebuttal could only happen at the merits stage, not certification. The court of appeals agreed with EPJ Fund and barred Halliburton from rebutting the presumption at certification, and Halliburton sought certiorari, also urging the Court to overturn the reliance presumption altogether.
Whether securities fraud defendants may rebut the presumption of investor reliance on a company's alleged misrepresentations at the class-certification stage using evidence that the misrepresentations had no impact on the stock's price.