With Lennis Collins, Andrew Escobar
In an opinion issued today in "Jones v. Harris Associates L.P.", 559 U.S. ___ (2010) (Alito, J.), the Supreme Court resolved a circuit split by unanimously affirming the standard set nearly three decades ago in "Gartenberg v. Merrill Lynch Asset Management, Inc.", for courts to assess claims by mutual fund shareholders under § 36(b) of the Investment Company Act of 1940.