Ernst & Ernst v. Hochfelder
E590643
Ernst & Ernst v. Hochfelder is a 1976 U.S. Supreme Court decision holding that private damages actions under SEC Rule 10b-5 require proof of scienter, not mere negligence.
All labels observed (2)
| Label | Occurrences |
|---|---|
| Ernst & Ernst v. Hochfelder canonical | 1 |
| Ernst & Ernst v. Hochfelder, 425 U.S. 185 (1976) | 1 |
How this entity was disambiguated
This entity first appeared as the object of triple T6409121 — resolving that mention is where its identity was fixed. The disambiguator weighed these candidate entities and picked the highlighted one (or “None”, minting a new entity). This is how homonymy is resolved: the same surface form can point to different entities.
NED1
Entity disambiguation (via context triple)
gpt-5-mini-2025-08-07
Target entity: Ernst & Ernst v. Hochfelder Context triple: [Section 10(b) of the Securities Exchange Act of 1934, relatedCaseLaw, Ernst & Ernst v. Hochfelder]
-
A.
Eisner v. Macomber
Eisner v. Macomber is a 1920 U.S. Supreme Court case that held a pro rata stock dividend was not taxable income under the Sixteenth Amendment, shaping early federal income tax doctrine.
-
B.
Lucas v. Earl
Lucas v. Earl is a landmark 1930 U.S. Supreme Court tax law case that established the principle that income is taxed to the person who earns it, regardless of contractual arrangements to split or assign that income.
-
C.
United States v. Arthur Andersen LLP
United States v. Arthur Andersen LLP was a landmark U.S. Supreme Court case overturning the criminal conviction of Enron’s accounting firm for obstruction of justice, significantly shaping standards for prosecuting corporate document destruction.
-
D.
Sibbach v. Wilson & Co.
Sibbach v. Wilson & Co. is a 1941 U.S. Supreme Court case that upheld the validity of the Federal Rules of Civil Procedure under the Rules Enabling Act and helped define the scope of federal procedural rulemaking.
-
E.
Argersinger v. Hamlin
Argersinger v. Hamlin is a 1972 U.S. Supreme Court case that extended the right to counsel to defendants in misdemeanor cases that may result in imprisonment.
- F. None of above. chosen
- G. Unsure - the case is ambiguous/there is not enough information to decide.
NED2
Entity disambiguation (via description)
gpt-5-mini-2025-08-07
Target entity: Ernst & Ernst v. Hochfelder Target entity description: Ernst & Ernst v. Hochfelder is a 1976 U.S. Supreme Court decision holding that private damages actions under SEC Rule 10b-5 require proof of scienter, not mere negligence.
-
A.
Eisner v. Macomber
Eisner v. Macomber is a 1920 U.S. Supreme Court case that held a pro rata stock dividend was not taxable income under the Sixteenth Amendment, shaping early federal income tax doctrine.
-
B.
Lucas v. Earl
Lucas v. Earl is a landmark 1930 U.S. Supreme Court tax law case that established the principle that income is taxed to the person who earns it, regardless of contractual arrangements to split or assign that income.
-
C.
United States v. Arthur Andersen LLP
United States v. Arthur Andersen LLP was a landmark U.S. Supreme Court case overturning the criminal conviction of Enron’s accounting firm for obstruction of justice, significantly shaping standards for prosecuting corporate document destruction.
-
D.
Sibbach v. Wilson & Co.
Sibbach v. Wilson & Co. is a 1941 U.S. Supreme Court case that upheld the validity of the Federal Rules of Civil Procedure under the Rules Enabling Act and helped define the scope of federal procedural rulemaking.
-
E.
Argersinger v. Hamlin
Argersinger v. Hamlin is a 1972 U.S. Supreme Court case that extended the right to counsel to defendants in misdemeanor cases that may result in imprisonment.
- F. None of above. chosen
Statements (43)
| Predicate | Object |
|---|---|
| instanceOf |
United States Supreme Court case
ⓘ
federal court decision ⓘ securities law case ⓘ |
| appliesTo | private plaintiffs seeking damages under Rule 10b-5 ⓘ |
| areaOfLaw |
federal securities fraud
ⓘ
securities regulation ⓘ |
| citation |
425 U.S. 185
ⓘ
47 L. Ed. 2d 668 ⓘ 96 S. Ct. 1375 ⓘ |
| citationStyle |
Ernst & Ernst v. Hochfelder, 425 U.S. 185 (1976)
ⓘ
linked to:
Ernst & Ernst v. Hochfelder
|
| clarified | mental state requirement for Rule 10b-5 liability ⓘ |
| country |
United States
ⓘ
linked to:
United States of America
|
| court | Supreme Court of the United States ⓘ |
| decisionDate | 1976-03-30 ⓘ |
| defendant |
Ernst & Ernst
ⓘ
linked to:
Ernst & Young
|
| defendantType | accounting firm ⓘ |
| definedConcept | scienter in the context of Rule 10b-5 ⓘ |
| distinguishedFrom | negligence-based securities claims under other provisions of the securities laws ⓘ |
| holding |
mere negligence is insufficient to establish liability in a private damages action under Rule 10b-5
ⓘ
private damages actions under SEC Rule 10b-5 require proof of scienter ⓘ scienter is a necessary element of a Rule 10b-5 private cause of action ⓘ |
| impact |
limited Rule 10b-5 private actions to intentional or reckless misconduct
ⓘ
raised the liability standard for private securities fraud actions under Rule 10b-5 ⓘ |
| issue |
whether negligence is sufficient for private damages liability under Rule 10b-5
ⓘ
whether scienter is required for a private cause of action under Section 10(b) and Rule 10b-5 ⓘ |
| jurisdiction | United States federal law ⓘ |
| language | English ⓘ |
| legalEffect | established scienter as an element of Rule 10b-5 private damages claims ⓘ |
| legalProvisionInterpreted |
SEC Rule 10b-5
ⓘ
linked to:
Rule 10b-5
Section 10(b) of the Securities Exchange Act of 1934 ⓘ |
| majorityOpinionBy |
Justice Lewis F. Powell Jr.
ⓘ
linked to:
Lewis F. Powell Jr.
|
| originatingCourt | United States Court of Appeals for the Seventh Circuit ⓘ |
| plaintiff | Hochfelder ⓘ |
| relatedConcept |
private securities fraud class actions
ⓘ
recklessness as a form of scienter ⓘ |
| result | judgment of the court of appeals was reversed ⓘ |
| reversed | United States Court of Appeals for the Seventh Circuit ⓘ |
| subjectMatter | private right of action under federal securities laws ⓘ |
| subsequentCitationBy |
Basic Inc. v. Levinson
ⓘ
Central Bank of Denver, N.A. v. First Interstate Bank of Denver, N.A. ⓘ Tellabs, Inc. v. Makor Issues & Rights, Ltd. ⓘ |
| term | 1975 Term ⓘ |
| vote | 6-3 ⓘ |
How these facts were elicited
The pipeline generated the facts above by prompting gpt-5.1 with this entity's name + description and the instruction below.
Instruction
You are a knowledge base construction expert. Given a subject entity and a description of it, return factual statements that you know for the subject as a JSON list of dictionaries(triples), where keys must be "subject", "predicate" and "object". The number of facts may be very high, between 25 to 50 or more, for very popular subjects. For less popular subjects, the number of facts can be very low, like 5 or 10. # Requirements - If you don't know the subject at all, return an empty list. - If the subject is not a named entity, return an empty list. - Include at least one triple where predicate is "instanceOf". - Do not get too wordy. - Separate several objects into multiple triples with one object.
Input
Subject: Ernst & Ernst v. Hochfelder Description of subject: Ernst & Ernst v. Hochfelder is a 1976 U.S. Supreme Court decision holding that private damages actions under SEC Rule 10b-5 require proof of scienter, not mere negligence.
Referenced by (2)
Full triples — surface form annotated when it differs from this entity's canonical label.
Section 10(b) of the Securities Exchange Act of 1934
→
relatedCaseLaw
→
Ernst & Ernst v. Hochfelder
ⓘ
linked to: Ernst & Ernst v. Hochfelder