PUBLIC COMPANY executives who are squeamish about Sarbanes-Oxley Act rules requiring them to personally certify complex financial documents can breathe a little easier, thanks to a recent federal appeals court decision.

The 11th U.S. Circuit Court of Appeals ruled on Oct. 12 that plaintiffs have to show that the executives acted with intent to deceive or were severely reckless. Robert Garfield v. NDCHealth Corp., No. 05-14765 11th Cir. Oct. 12, 2006.

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