Citigroup, Inc. v. Ottos Candies

On January 12, 2026, the Supreme Court declined to review an Eleventh Circuit decision allowing civil-RICO claims premised on conduct actionable as securities fraud. The decision was a disappointment for WLF, which urged review in its amicus brief contending that the PSLRA’s express bar under 18 U.S.C. § 1964(c) prohibits such claims regardless of a given plaintiff’s standing to sue under federal securities law. WLF’s brief was prepared with the pro bono assistance of Douglas W. Greene, Brian W. Song, Bari R. Nadworthy, and Renee M. Knudsen of BakerHostetler.