Cyan, Inc. v. Beaver County Employees Retirement Fund

138 S. Ct. 1061, 200 L. Ed. 2d 332 (2018)

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Cyan, Inc. v. Beaver County Employees Retirement Fund

United States Supreme Court
138 S. Ct. 1061, 200 L. Ed. 2d 332 (2018)

Facts

Beaver County Employees Retirement Fund and an individual (investors) (plaintiffs) bought shares of Cyan, Inc. (Cyan) (defendant) through an initial public offering. After Cyan’s stock price dropped, the investors filed a class action against Cyan in state court. The investors alleged that Cyan violated federal law, specifically the Securities Act of 1933, by making false statements in the initial public offering documents. The investors did not make any claims against Cyan under state law. Cyan motioned to dismiss the class action, arguing that the state court lacked subject-matter jurisdiction over the investor’s federal law claims. The state court denied Cyan’s motion. Cyan appealed. The federal government (amicus curiae) joined the appeal, arguing that Cyan could have removed the class action from state court to federal court.

Rule of Law

Issue

Holding and Reasoning (Kagan, J.)

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