United States Court of Appeals for the Second Circuit
773 F.3d 438 (2014)
Financial analysts at various firms obtained non-public information from corporate insiders. The analysts knew the insiders as family friends, casual acquaintances, or fellow business school alumni. With one exception involving the mutual sharing of career advice, the insiders received nothing in exchange for their disclosures to the analysts. Todd Newman and Anthony Chiasson (defendants) were fund managers several levels removed from the disclosing corporate insiders. They received and traded on the inside information. The U.S. government (plaintiff) charged Newman and Chiasson with securities fraud. The district court instructed the jury that, in order for it to reach a guilty verdict, the defendants had to have known that the corporate insiders disclosed material, non-public information. Newman and Chiasson were convicted. They appealed, arguing that the jury instructions were improper and that the government had failed to prove that they knew that the corporate insiders had obtained a personal benefit in exchange for their disclosure.
Rule of Law
Holding and Reasoning (Parker, J.)
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