Pleading Corporate Scienter: Does Janus Inform the Analysis?

Two recent cases from the Southern District of New York discussed the application of the Supreme Court’s opinion in Janus to pleading corporate scienter in Reform Act cases.  Judge Pauley, in Pennsylvania Public School Employee’s Retirement System v. Bank of America Corporation, came to the conclusion that Janus does not inform the pleading of corporate scienter, although perhaps only on procedural grounds.  Judge Sullivan in In re UBS AG Securities Litigation, came to…