Fourth Circuit Reverses Class Certification In Boeing Securities Fraud Case

In Short

The Situation: In State of Rhode Island Office of the General Treasurer v. The Boeing Company, No. 25-1492 (4th Cir. July 20, 2026), the Fourth Circuit opined on the level of proof that securities class-action plaintiffs, at the time of class certification, need to provide concerning their damages methodology in order to meet the standard articulated in Comcast Corp. v. Behrend, 569 U.S. 27 (2013).

The Result: The Fourth Circuit held that the plaintiffs' proof was insufficient because their damages expert offered only a "menu of options" rather than a specific methodology shown to be consistent with the plaintiffs' liability theory.

Looking Ahead: This decision establishes the Fourth Circuit as having a rigorous standard for evaluating damages methodologies at the class-certification stage in securities fraud cases. Both within and outside the Fourth Circuit, the Boeing decision will be an important tool for defendants seeking to defeat class certification in securities