Pricewaterhousecoopers, LLP, et al. v. Bhatia, et al., No. 13-1642 (2d Cir. 2014)Annotate this Case
Non-Settling Defendants seek to overturn a partial final judgment approving the settlement of certain putative class actions. The settled claims were brought by Investor Plaintiffs who were individual and institutional investors in so-called Bernard Madoff feeder funds managed by the Fairfield Greenwich Group (Settling Defendants). The Non-Settling Defendants challenged a provision in the settlement agreement that provides that investors who filed claims under the settlement submit to the district court's jurisdiction for the sole purpose of participating in the settlement and not for any other purpose. The court joined its sister circuits in holding that a settlement which does not prevent the later assertion of a non-settling party's claims, does not cause the non-settling party "formal" legal prejudice. Therefore, the court concluded that the Non-Settling Defendants did not have standing to object to the settlement. The court declined to address the remaining issues on appeal and dismissed for lack of standing.