United Ass'n of Black Landscapers v. City of Milwaukee

How later courts describe this case

• holding that school districts do not share in the Commonwealth of Pennsylvania's Eleventh Amendment sovereign immunity, because they are not alter egos of the Commonwealth
• accountant’s receipt of substantial fees for its services “not sufficient to support an inference of scienter”
• court held that assertions that the defendant had knowledge of the misstatements “are nothing more than rote conclusions”
• exhaustion appropriate where issues involved were purely legal, not factual