Halliburton Co. v. Erica P. John Fund, Inc., 573 U.S. 258 (2014), is a United States Supreme Court case regarding class action certification for a securities fraud claim.

Halliburton CEO Dick Cheney arranged a merger with competitor Dresser Industries, which had been directed for decades by Prescott Bush.

[4] When Halliburton publicly revealed its asbestos liabilities its stock dropped 72%[5] The Archbishop sued, bringing a class action in the Dallas federal district court, alleging securities fraud.

SEC Rule 10b-5 securities fraud requires a private plaintiff to prove that her economic loss was caused by reliance on the defendant's material misrepresentation.

Finding the fraud on the market presumption only addresses members’ common reliance, the Court held that plaintiffs did not need to prove loss causation when seeking class certification.

Furthermore, Roberts notes that stare decisis has special force because Congress is free to change the Basic presumption, and subsequently has chosen not to do so despite two major securities fraud reforms.

[6] Instead of burdening plaintiffs, Roberts decides that defendants should be able to rebut the reliance presumption with evidence of a lack of price impact before class certification.

Noting that on merits only six defendants have successfully rebutted individual plaintiffs’ reliance on price integrity, Thomas fears that the Basic presumption in practice is “largely irrebuttable”.

[13] What's worse for Thomas, the huge damages resulting from securities fraud creates “substantial in terrorem settlement pressures” for large publicly traded companies to pay deceived shareholders.

[14] Concluding that reliance in security fraud is “inherently individualized”, Thomas would overrule Basic and require every deceived shareholder to sue separately.