The concern of the securities class action bar that the U.S. Supreme Court would issue yet another ruling to impede the pleading or proving of securities fraud cases has dissipated.

In Halliburton v. Erica P. John Fund, the court unanimously rejected an attack on its 25-year-old precedent, Basic v. Levinson, sustaining its fraud-on-the market presumption of reliance on misrepresentations at class certification. However, the court created the opportunity for the defendant to rebut that presumption at the certification hearing, by showing a lack of price impact.