Mealey's (March 27, 2018, 12:47 PM EDT) -- BOSTON — A First Circuit U.S. Court of Appeals panel on March 23 affirmed dismissal of a lawsuit accusing a short value fund management firm of breaching its fiduciary duty under the Employee Retirement Income Security Act by imprudently managing the fund, finding that the plaintiffs failed to sufficiently allege that the firm’s actions departed radically from the common investing approaches to those types of funds (Mary Barchock v. CVS Health Corp., et al., No. 17-1515, 1st Cir., 2018 U.S. App. LEXIS 7430)....