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West Virginia Pipe Trades Health & Welfare Fund v. Medtronic, Inc.
United States Court of Appeals for the Eighth Circuit
845 F.3d 384 (2016)
Medtronic, Inc. (defendant) developed a procedure called INFUSE as an alternative to bone grafting. The U.S. Food and Drug Administration (FDA) approved the procedure based on several medical-journal articles discussing clinical trials of INFUSE. The trials had been run by Medtronic, and it was later revealed that the articles were written by doctors with financial interests in INFUSE. West Virginia Pipe Trades Health & Welfare Fund (the fund) (plaintiff), a Medtronic investor, brought a securities class action, alleging that Medtronic had engaged in a scheme to defraud investors based on Securities and Exchange Commission Rule 10b-5(a) and (c). The fund alleged that Medtronic paid the authors of the articles to downplay the downsides of INFUSE and overstate the shortcomings of bone grafting. The district court granted Medtronic’s motion for summary judgment. The fund appealed.
Rule of Law
Holding and Reasoning (Gruender, J.)
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