Mealey's (March 31, 2020, 2:20 PM EDT) -- NEW YORK — A Second Circuit U.S. Court of Appeals panel on March 30 ruled that although a convicted tipper’s counsel failed to properly advise his client on the “personal-benefit” element of the insider trading charge against him before pleading to conspiracy to commit securities fraud, based on the defendant’s lack of benefit defense, he has failed to show that there was a reasonable probability that he would be chosen to proceed to trial on the charges against him had he been made aware of the requirement (John Marshall v. United States of America, No. 19-937, 2nd Cir., 2020 U.S. App. LEXIS 9730)....