Carpenters' Pension Fund of Illinois v. Target Corp., No. 18-1831 (8th Cir. 2020)
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Investors who purchase Target Corporation stock filed suit against Target and its executives, alleging that Target misled investors about problems in its Canadian stores. Investors' claims stemmed from Target's efforts to open stores in Canada.
The Eighth Circuit affirmed the district court's dismissal, and denial of investors' motion for reconsideration and leave to amend. The court held that the district court did not err in determining that investors failed to plead fraud with particularity under the Private Securities Litigation Reform Act of 1995 (PSLRA). In this case, none of the investors' allegations satisfied the PSLRA's mental state requirement and, for one allegation, its falsity requirement. The court also held that the district court did not abuse its discretion in denying leave to amend, because investors failed to allege that Target's executives knew they were making false or misleading statements to investors. Finally, the court held that, because investors' section 10(b) of the Securities and Exchange Act of 1934 claim failed, dismissal of their section 20(a) claim was also appropriate.
Court Description: [Kobes, Author, with Shepherd and Grasz, Circuit Judges] Civil case - Securities. The district court did not err in determining plaintiff investors had failed to plead fraud with the particularity needed under the Private Securities Litigation Reform Act of 1995 to survive a motion to dismiss; none of plaintiffs' allegations satisfied the PSLRA's mental state requirements and, for one allegation, its falsity requirement; the court did not abuse its discretion in denying leave to file a second amended complaint as it still failed to allege that Target's executives knew they were making false statements about Target Canada.
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