Mealey's (May 6, 2020, 2:00 PM EDT) -- NEW YORK — A federal district court did not err in dismissing a shareholder lawsuit against a real estate investment trust (REIT), its adviser and others for failure to state a claim for relief because the REIT was under no duty to disclose in the proxy materials for its proposed merger agreement and new advisory agreement with its external adviser how the trust would be managed under the agreements, a Second Circuit U.S. Court of Appeals panel ruled May 5 (Carolyn St. Clair-Hibbard v. American Finance Trust Inc., et al., No. 19-3078, 2nd Cir., 2020 U.S. App. LEXIS 14319)....