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Advertisement Rebutting the Presumption of Class-Wide Reliance at the Class Certification Stage: Analysis of and Key Takeaways From Arkansas Teacher Ret. Sys. V. Goldman Sachs Grp., Inc. and the Supreme Court’s Recent Grant of Certiorari Thursday, December 17, 2020 Since the Supreme Court’s decision in Basic Inc. v. Levinson, 485 U.S. 224 (1988), plaintiffs have been permitted to invoke a rebuttable presumption of class-wide reliance at the class certification stage in securities fraud cases, thereby skirting any obligation to establish individualized reliance for each member of the proposed class. In Halliburton Co. v. Erica P. John Fund, Inc., 573 U.S. 258 (2014) , the Supreme Court clarified that defendants must be afforded an opportunity to rebut this presumption, and cautioned judges not to “artificially limit” the types of rebuttal evidence a defendant may offer, even if such evidence “is also highly relevant at the merits s ....