11th Circ. NextEra Ruling Broadens Loss Causation Standard

The Eleventh Circuit’s decision in Jastram v. NextEra Energy Inc. signals a meaningful shift in how courts may evaluate loss causation at the pleading stage in securities fraud cases. Reversing a dismissal, the court held that the key question is whether “enough truth has saturated the market” to prompt investors to reassess prior statements, even without a direct admission of falsity, adopting a cumulative, market-focused approach to corrective disclosures. In this Law360 article, Ian Ross, a partner in Sidley’s Consumer Class Actions, ERISA and Insurance Litigation practice, and Ava Gruener, an associate in the firm’s Commercial Litigation and Disputes practice, analyze the ruling and outline what it means for securities defendants, motion to dismiss strategy, and the potential trajectory of securities litigation in the Eleventh Circuit.