Michiana Area Electrical Workers' Pension Fund v. Inari Medical, Inc.
- Gregory Woods
- 1:24-cv-03686
- U.S. District Court · Southern District of New York
- 5
In Michiana Area Electrical Workers’ Pension Fund v. Inari Medical, Magistrate Judge Willis granted consolidation of two securities actions and directed an expedited hearing transcript.
The two groups of securities plaintiffs, the defendants, and the parties seeking appointment as lead plaintiffs or lead counsel are affected because the two lawsuits will proceed as one consolidated action; the order does not decide the underlying securities claims.
What happened
Michiana Area Electrical Workers’ Pension Fund v. Inari Medical, Inc. and Paul Hartmann brought two securities lawsuits against the same defendants, alleging that Inari failed to disclose an alleged bribery scheme that caused investor losses.
Both plaintiffs asked the court to combine the lawsuits. They also asked the court to appoint lead plaintiffs and lead lawyers, and the court held oral argument on those requests.
Magistrate Judge Willis granted the motions to consolidate under Rule 42(a), directing that the newer Hartmann case be combined with the older Michiana case. The court also directed the parties to provide an expedited transcript of the oral argument.
The detailed version
- Michiana Area Electrical Workers' Pension Fund v. Inari Medical, Inc. · No. 1:24-cv-03686
- Gregory Woods
- Mar. 19, 2025
Background
Michiana Area Electrical Workers’ Pension Fund filed the first securities action on May 13, 2024. Paul Hartmann filed the second action on June 18, 2024. Both actions named Inari Medical, Inc., William Hoffman, Andrew Hykes, and Mitch C. Hill as defendants and alleged that the defendants failed to disclose an alleged bribery scheme, causing investors to suffer financial losses.
The complaints asserted claims under Sections 10(b) and 20(a) of the Securities Exchange Act. Michiana brought its action individually and on behalf of other similarly situated parties. Michiana was joined in its consolidation and lead-plaintiff motions by Oklahoma Law Enforcement Retirement System and City of Pontiac Reestablished General Employees’ Retirement System.
Motions and Legal Standard
Hartmann moved to consolidate the two actions and asked to be appointed lead plaintiff and for his counsel to be appointed lead counsel. Michiana and the other pension funds also moved to consolidate and sought appointment of the Pension Funds and their counsel as lead plaintiffs and lead counsel. Arvin Nazerzadeh-Yazdi withdrew a separate motion to consolidate and seek appointment after determining that he did not have the largest financial interest in the litigation.
Under Federal Rule of Civil Procedure 42(a), a court may consolidate actions involving a common question of law or fact. The court explained that consolidation should promote judicial efficiency, speed, and reduced costs while preserving a fair and impartial trial. The Private Securities Litigation Reform Act also requires a court to decide whether related securities actions should be consolidated before selecting a lead plaintiff.
Court’s Analysis
The court found that the two actions involved the same defendants, allegations, claims, and alleged bribery scheme. The court therefore determined that the cases involved common questions of law and fact. It also noted that the defendants had not opposed consolidation, which weighed against a finding of potential prejudice.
Ruling
The court granted the motions to consolidate. The Clerk of Court was directed to consolidate Hartmann v. Inari Medical, Inc., et al., No. 24-CV-4662 (JHR) (JW), under the older Michiana action, No. 24-CV-3686 (JHR) (JW). The court also directed the parties to order an expedited copy of the transcript of the March 19, 2025 oral argument and provide it to the court. The order does not state a ruling on the competing requests for appointment of lead plaintiffs or lead counsel.
Read the full 5-page opinion on CourtListener, the free public archive maintained by the Free Law Project.