In Cyan, Inc., the Justices unanimously decide that state courts have jurisdiction over federal Securities Act class actions.
Key Points:
..Resolves split of authority on whether the Securities Litigation Uniform Standards Act of 1998 (SLUSA) divested state courts of subject matter jurisdiction over “covered class actions” if the plaintiff alleges only federal Securities Act claims.
..Despite commentary at oral argument that statute was “obtuse” and “gibberish” the Supreme Court determined that “SLUSA’s text, read most straightforwardly,” leaves the state court jurisdiction intact.
..Beyond the textual argument, the Supreme Court also held that the legislative history supports its conclusion because the focus of SLUSA was to limit the conduct of securities class actions under state law.
..The Supreme Court also resolved an issue raised by the Federal Government as amicus curiae, concluding that SLUSA does not permit defendants to remove to federal court purported class actions alleging only Securities Act claims.
..While the decision will likely lead to more Securities Act cases being filed in state court, it may reduce forum shopping between those courts in different states.
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