Shupe v. Rocket Companies, Inc.

CourtDistrict Court, E.D. Michigan
DecidedApril 17, 2025
Docket1:21-cv-11528
StatusUnknown

This text of Shupe v. Rocket Companies, Inc. (Shupe v. Rocket Companies, Inc.) is published on Counsel Stack Legal Research, covering District Court, E.D. Michigan primary law. Counsel Stack provides free access to over 12 million legal documents including statutes, case law, regulations, and constitutions.

Bluebook
Shupe v. Rocket Companies, Inc., (E.D. Mich. 2025).

Opinion

UNITED STATES DISTRICT COURT EASTERN DISTRICT OF MICHIGAN NORTHERN DIVISION

CONSTRUCTION LABORERS PENSION TRUST FOR SOUTHERN CALIFORNIA,

Plaintiff, Case No. 1:21-cv-11528

v. Honorable Thomas L. Ludington United States District Judge ROCKET COMPANIES, INC., JAY FARNER, DANIEL GILBERT, and ROCKET HOLDINGS, INC.,

Defendants. ____________________________________________/

OPINION AND ORDER (1) GRANTING PLAINTIFF’S MOTION FOR LEAVE TO FILE A RENEWED MOTION FOR CLASS CERTIFICATION, (2) DIRECTING PLAINTIFF TO FILE SUPPLEMENTAL BRIEFING, AND (3) CLARIFYING THE NEED FOR FURTHER PSLRA LEAD PLAINTIFF PROCEEDINGS

Carl Shupe and Construction Laborers Pension Trust for Southern California (“SoCal”) sought to certify a nationwide class of Rocket Companies, Inc. (“Rocket”) shareholders alleging that Rocket, its holding company Rocket Holdings, Inc. (“RHI”), its CEO Jay Farner, and its founder Dan Gilbert, violated the Securities Exchange Act through fraudulent misrepresentations and insider trading. Shupe sought to represent the broader Class, and SoCal sought to represent a Subclass of those shareholders who traded “contemporaneously” with Defendant Gilbert’s alleged March 2021 insider trade. But, in late September 2024, this Court denied class certification. This Court concluded that individual questions of investor reliance predominated throughout the broader class’s fraudulent misrepresentation claims. And this Court concluded both Shupe and SoCal were inadequate representatives, for different reasons: Shupe was dishonest and SoCal was uninformed. The pleadings since this decision have been puzzling. SoCal—but not Shupe—filed a hybrid motion. Primarily, the motion seeks leave to file a renewed motion for class certification. In that forthcoming renewed motion, SoCal explains, it will abandon all fraudulent misrepresentation claims and will instead seek to certify a “narrowed” class of only those Rocket

shareholders who are able to advance the insider trading claims. Alternatively, SoCal seeks reconsideration of this Court’s decision declining to certify the insider trading Subclass. Two days later SoCal—but not Shupe—filed a petition for a permissive interlocutory appeal in the Sixth Circuit, only to then immediately file a motion in the Sixth Circuit seeking to hold that petition in abeyance pending this Court’s ruling on its hybrid motion for leave or reconsideration. And, nearly two months after this motion practice, the Parties filed a stipulation in this Court that, in part, voluntarily dismissed all of Shupe’s claims. As explained below, SoCal does not need this Court’s leave to file a renewed motion for class certification. Civil Rule 23 permits a plaintiff to take multiple bites at the class-certification apple. But, in securities class actions, the Private Securities Litigation Reform Act (PSLRA)

requires these bites to be taken by a designated lead plaintiff. SoCal is not a PSLRA lead Plaintiff. Carl Shupe was, before he dismissed his claims. So, if SoCal wishes to proceed with putative class allegations—despite this Court’s prior denial and SoCal’s pending appellate petition—PSLRA proceedings must be reopened. I.

This Court outlined all background facts and this case’s complicated procedural posture in its September 2024 Opinion & Order denying class certification. See Shupe v. Rocket Companies, Inc., 752 F. Supp. 3d 735, 752–60. Such background need not be recounted in full here. Only the key facts follow. A. In their amended February 2024 Complaint, Shupe and SoCal advanced four claims. In Count I, they alleged Defendant RHI committed insider trading when Defendant Gilbert—RHI’s majority shareholder and Chairman—sold shares of Rocket Class A common stock on March 29,

2021 armed with material, non-public information about Rocket's financial forecast. Id. at 758–59 (enumerating “[t]en details” that “illustrate the unusual nature” of Gilbert’s trade). In Count II, Shupe and SoCal alleged that SoCal—and other similarly situated shareholders—traded Rocket Class A common stock “contemporaneously” with Gilbert’s insider trade such that they may recover from RHI under Section 20A of the Exchange Act. Id. at 759. In Count III, Shupe and SoCal alleged that Defendant Rocket— through its CEO Farner—defrauded the market in violation of the Exchange Act through a series of materially false and misleading statements that artificially inflated and maintained the prices of Rocket Class A common stock. Id.; see also id. at 756–57 (outlining Farner’s alleged fraudulent misrepresentations). And, in Count IV, Shupe and SoCal alleged Defendants RHI and Gilbert effectively controlled Rocket, and are thus similarly

liable for Farner’s false and misleading misrepresentations as “controllers”. Id. at 759. These claims are summarized in the following table for clarity: Count Claim Defendants I Insider Trading; RHI Section 10(b) and Rule 10b-5 of the Exchange Act II Private Right of Action For “Contemporaneous” Traders; RHI Section 20A of the Exchange Act III Materially False and Misleading Statements; Rocket, Farner Section 10(b) and Rule 10b-5 of the Exchange Act IV Materially False and Misleading Statements—Controller Liability; RHI, Gilbert Section 20(a) of the Exchange Act

On February 12, 2024, Shupe and SoCal sought class certification. ECF No. 111. Shupe sought to represent the following proposed Class: All persons and entities that purchased or otherwise acquired publicly traded Rocket Companies, Inc. (“Rocket” or the “Company”) Class A common stock (NYSE: RKT) between February 25, 2021 and May 5, 2021, inclusive (the “Class Period”), and were damaged thereby[.] Excluded from the Class are: (a) Defendants;1 (b) members of the immediate families of Defendants; (c) the subsidiaries and affiliates of Defendant Rocket and Defendant RHI; (d) any person who is an officer, director, or controlling person of Rocket; (e) any entity in which any Defendant has a controlling interest; and (f) the legal representatives, heirs, successors, or assigns of any such excluded party.

ECF No. 111 at PageID.8589. And, relevant to the §20A insider trading claim for “contemporaneous” traders—Count II—SoCal sought to represent the following proposed Subclass: All persons and entities within the Class that purchased publicly traded Rocket Class A common stock contemporaneously with Defendant Gilbert's and Defendant RHI's sale of Rocket Class A common stock on March 29, 2021[.] Excluded from the Subclass are: (a) Defendants; (b) members of the immediate families of Defendants; (c) the subsidiaries and affiliates of Defendant Rocket and Defendant RHI; (d) any person who is an officer, director, or controlling person of Rocket; (e) any entity in which any Defendant has a controlling interest; and (f) the legal representatives, heirs, successors, or assigns of any such excluded party.

Id. at PageID.8589–90.

B.

But, on September 30, 2024, this Court concluded Shupe and SoCal “c[a]me up short” and that the Proposed Class and Subclass only satisfied three of the seven Rule 23 requirements for class certification.1 Shupe, 752 F. Supp. 3d. at 752. Each of the four requirements Shupe and SoCal failed to satisfy will be summarized in turn. 1. Rule 23(b)(3) Predominance Start with Civil Rule 23(b)’s “crucial” requirement that common questions of law and fact “predominate” over individual questions asserted by members of the putative class. Id. at 761–62;

1 This Court concluded that the proposed Class and Subclass satisfied Civil Rule 23(a)’s numerosity, commonality, and typicality requirements. See Shupe, 752 F. Supp. 3d at 787–91. FED. R. CIV. P. 23(b).

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