Waterford Township Police & Fire Retirement System v. CVS Health Corporation

CourtDistrict Court, D. Rhode Island
DecidedFebruary 5, 2025
Docket1:19-cv-00434
StatusUnknown

This text of Waterford Township Police & Fire Retirement System v. CVS Health Corporation (Waterford Township Police & Fire Retirement System v. CVS Health Corporation) is published on Counsel Stack Legal Research, covering District Court, D. Rhode Island primary law. Counsel Stack provides free access to over 12 million legal documents including statutes, case law, regulations, and constitutions.

Bluebook
Waterford Township Police & Fire Retirement System v. CVS Health Corporation, (D.R.I. 2025).

Opinion

UNITED STATES DISTRICT COURT FOR THE DISTRICT OF RHODE ISLAND

____________________________________ ) ) ) IN RE CVS HEALTH ) CORPORATION SECURITIES ) No. 1:19-cv-434-MSM-LDA ACT LITIGATION ) ) ) ____________________________________)

MEMORANDUM AND ORDER

Mary S. McElroy, United States District Judge.

I. INTRODUCTION This is the second of two securities cases challenging practices of the CVS Health Corporation (“CVS”) and its officers and agents to come before this Court. In 2019, this case was filed as a putative class action by the Waterford (Connecticut) Township Police & Fire Retirement System (“Waterford”) seeking to impose liability on CVS for what it claimed were false and misleading statements surrounding CVS’s 2018 acquisition of Aetna Insurance Corporation. Waterford, like other retirement funds joining in the action, was an investor in Aetna whose stock was exchanged for CVS shares as part of the merger. The same year this lawsuit was filed, a group of pension funds that had been investors in Omnicare Corporation, a company acquired by CVS in 2015, also sued CVS for what it similarly claimed were false and misleading statements CVS had made in connection with the Omnicare acquisition. The lead plaintiff in that case was the City of Miami (Florida) Firefighters’ and Police Officers’ Retirement Trust. Both the Omnicare and Aetna acquisitions were part of a larger effort by CVS,

according to the lawsuits, to expand its dominance in the pharmaceutical arena of the long-term care world by diversifying its services. Prior to the Omnicare merger, CVS’s market share was largely in its retail business, anchored by its brick-and- mortar stores. Omnicare brought it a new customer base of long-term care facilities to which it sold pharmaceuticals. The acquisition of Aetna took it into the insurance world.

The two lawsuits shared common themes. Each contended that the documents CVS was required by law to file in connection with the acquisitions contained false statements and omitted facts that were so material that their omission made other statements misleading. Each contended that CVS painted an overly rosy picture of its operations to convince shareholders of the companies it was acquiring to vote for the merger. Each maintained that CVS’s stock had lost value because of the Omnicare acquisition. The Omnicare shareholders complained that CVS’s business

practices had decimated the value of what Omnicare had brought to the merger. The Aetna shareholders complained that CVS’s valuation, in convincing them of the favorability of their merger with CVS, failed to accurately inform them of the losses the Omnicare acquisition had caused to CVS’s Retail/Long-Term Care unit. Both lawsuits complained that CVS had concealed the impact of losses of Omnicare’s value by writing down losses in Omnicare goodwill too late and too slowly. The relationship between the two acquisitions, and the two lawsuits, was summarized by the First Circuit in upholding this Court’s dismissal of the Omnicare (City of Miami) lawsuit:

CVS Health is a publicly traded company that provides integrated pharmacy healthcare services and operates thousands of retail stores and clinics across the United States. In 2015, CVS Health acquired Omnicare, then the leading provider of pharmaceutical services to long- term care (LTC) facilities. Plaintiffs allege that the newly acquired LTC business subsequently “hemorrhaged” customers due to CVS Health’s mismanagement, including its decision to centralize and standardize a number of operations that Omnicare had previously tailored to each customer. According to the complaint, CVS Health misleadingly concealed these customer losses and their causes so as not to threaten CVS Health’s ability to acquire financing for another large acquisition planned for 2018.

46 F.4th 22, 26 (1st Cir. 2022). That other “large acquisition planned for 2018” was the acquisition of Aetna. The First Circuit’s opinion in provides an obvious and instructive guide for the review of the instant Complaint, one against which the assessment of the Complaint both begins and ends. Because of likely impact, this Waterford litigation was stayed while was pending on appeal. After it was decided, these plaintiffs filed an Amended Complaint (ECF No. 51), which is the operative Complaint. For the same reason that prompted the First Circuit to affirm the dismissal of and in the context of pleadings that are similar in relevant respect, the Court finds the Amended Complaint wanting under Fed. R. Civ. P. 12(b)(6) and GRANTS the Motions to Dismiss (ECF Nos. 52, 53). II. DISCUSSION

A. Elements of the Action This action claims liability on the part of CVS Health under (a) Sections 11, 12(a)(2) and 15 of the Securities Act, 15 U.S.C. § § 77k, 77l and 77o; and (b) Sections 14(a) and 20(a) of the Exchange Act, 15 U.S.C. § § 78n(a) and 78t(a). None of these sections require that acts be committed with fraudulent intent, but they all impose liability for statements which are false because they are untrue or are misleading because they omit information or facts necessary to make the statement not misleading. While the formulations of this element—falsity or misleading nature—

vary slightly from statute to statute, the essence and defining words are the same.1 In the First Circuit focused on what allegations of pleading would adequately make out a claim for false or misleading statements, even taking the facts pled in the light most favorable to the plaintiff. 46 F.4th at 30. When the

1 Section 11 of the Securities Act, 15 U.S.C. § 77k, imposes liability on those signing or named in a Registration Statement “for untrue statement[s] of a material fact or omission of a material fact required to be stated therein or necessary to make the statements therein not misleading ….” Section 12(a)(2), 15 U.S.C. § 77l(a)(2), which governs communications in a prospectus and oral statements, proscribes “an untrue statement of a material fact or [omission of] a material fact necessary in order to make the statements, in the light of the circumstances under which they were made, not misleading ….” Section 14(a) of the Securities Exchange Act of 1934, 15 U.S.C. § 77o, governs solicitation of proxies by communications ““containing any statement which, at the time and in the light of the circumstances under which it is made, is false or misleading with respect to any material fact, or which omits to state any material fact necessary in order to make the statements therein not false or misleading ….” Finally, both Section 15 of the Securities Act and Section 20(a) of the Exchange Act impose derivative liability on those who control persons violating certain of the above statutes, thus necessarily incorporating the same false or misleading statement element. facts alleged in this Waterford case are compared to those found wanting in the Court reaches a similar result—dismissal for failure to state a claim upon which relief can be granted. That comparison is made below.

The plaintiffs argue that is not controlling for two reasons. First, they claim that the statutes under which liability was claimed in required proof of fraudulent intent, and those proscribing the conduct at issue here do not. 82 F.3d 1194, 1223 (1st Cir.

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Waterford Township Police & Fire Retirement System v. CVS Health Corporation, Counsel Stack Legal Research, https://law.counselstack.com/opinion/waterford-township-police-fire-retirement-system-v-cvs-health-rid-2025.