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

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