Rowe v. Allied Chemical Hourly Employees' Pension Plan

How later courts describe this case

• stating that plaintiff did not meet burden when it pled in very general terms, and did not allege who made or received fraudulent statements
• permitting amendment of RICO complaint which failed to plead predicate acts of mail and wire fraud with sufficient particularity under Rule 9(b)
• blanket allegation of mail and wire fraud in RICO case, without indicating who made or received fraudulent representation, is insufficient under Rule 9(b)
• complaint dismissed where it alleged “the general content of the representations,” but did not specify “who the speakers were ... or who received the information ... ”
• multiple inducements to retire made to thirty-two retirees over roughly six months
• vacated for reconsideration in light of Supreme Court’s decision in Firestone
• Rule 9(b) requires “detailed allegations” of fraud