Fourth Circuit affirms dismissal of claim based on unreliability of untrue statements made by former Governor McAuliffe and President Clinton's late brother-in-law

In Bi v. McAuliffe, the Fourth Circuit in an opinion by Judge Wilkinson, joined by Judges Niemeyer and Duncan, affirmed the dismissal by Judge Hilton of the fraud claims of a group of Chinese investors against Terry McAuliffy and Tony Rodham.

The opinion concluded that the allegations of misrepresentations were sufficient, but the plaintiffs failed to allege sufficient facts to show reasonable reliance, since many of them didn't speak English and also there were writings distributed to the investors that disclaimed what McAuliffe and Rodham were saying in their sales talks.