Cole A Goodman

January 10, 2020 | New York Law Journal

'Malouf' was the first foray by a federal court of appeals into "scheme liability" post-'Lorenzo', but the case involved a highly unusual fact pattern. Although the Tenth Circuit appeared to take a broad view of 'Lorenzo', lower courts and litigants should be careful not to overread the decision.

By Christopher P. Conniff, Gregory L. Demers and Cole A. Goodman 

9 minute read