United States v. Van Dyne

How courts have described this case

Verbatim parenthetical descriptions written by other courts when citing this decision. Ranked by citation-network relevance.

• alleging poor documentation practices at the audited company, with little more, is more likely to generate an inference of a “negligent audit rather than scienter”
• “To allege a ‘strong inference of deliberate recklessness,’ Appellants ‘must state facts that come closer to demonstrating intent, as opposed to mere motive and opportunity.’ ”
• “[T]he mere publication of inaccurate accounting figures, or a failure to follow GAAP, without more, does not establish scienter” in a securities fraud action (internal quotation marks omitted)
• “Thus, mere allegations that an accountant negligently failed to closely review files or follow GAAP cannot raise a strong inference of scienter.”

Source: CourtListener parenthetical corpus (CC0).