October Term 2025 · Docket 24-345

Does Section 47(b) of the Investment Company Act create a private right to sue?

FS Credit Opportunities Corp. says the statute's text does not clearly authorize investors to sue over fee arrangements. Saba Capital Master Fund says the statute's own words support such a suit. The Supreme Court must decide how to read Section 47(b).

Official caption
FS Credit Opportunities Corp. v. Saba Capital Master Fund
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Verified source milestones

  1. — An official oral-argument transcript was verified.
  2. — An official oral-argument transcript was verified.
  3. — An official Court opinion was verified.
  4. — An official Court opinion was verified.

The arguments, in order

This case may have been argued more than once. Each entry below uses that session's official transcript. Later arguments do not erase earlier ones.

  1. Argument 1 ·

    What happened at the argument

    Mr. Dvoretzky, for FS Credit Opportunities Corp. , argued Congress would have needed to speak clearly and unambiguously to imply a private right of action in Section 47(b). He said the statute's text does not meet that bar.

    Mr. Schulman, for Saba Capital Master Fund, argued most statutes fail the stringent test for implying a private right of action. He said Section 47(b)'s text does not unambiguously create new rights or focus unmistakably on individual plaintiffs.

    Mr. Clement, for Saba Capital Master Fund, argued this is not primarily an implied cause of action case. He said Section 47(b) contains express text of about 150 words, and the question is the best reading of that text.

    Mr. Dvoretzky argued the statute would be a roundabout way to write a cause of action. He said Congress could easily have specified who can sue, for what remedy, and against whom.

    Read the official transcript for this argument · Official argument details

    Sources used for this argument breakdown

A citizen's guide to the whole case

What this case is about

The dispute centers on whether Section 47(b) of the Investment Company Act of 1940 allows private parties to sue. FS Credit Opportunities Corp. argues Congress would have needed to speak clearly to create this right and did not. Saba Capital Master Fund argues the statute's text itself supports the claim.

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How the case got here

A lower court ruled in favor of Saba Capital Master Fund. FS Credit Opportunities Corp. asked the Supreme Court to review the case.

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What each side wants

FS Credit Opportunities Corp. argues Section 47(b) does not meet the high bar for an implied private right of action. It says Congress did not clearly specify who may sue, for what remedy, or against whom.

Saba Capital Master Fund argues the statute's text contains express language supporting a private right to sue. It says the question is the best reading of the statutory text.

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What each side says

Justice Sotomayor questioned whether the statute's text and structure show Congress intended to create a private right of action.

Justice Barrett questioned whether the proposed reading would be an innovation not expressly adopted in the Court's implied cause of action cases. She also questioned whether the clear statement rule requires a clear statement in all cases. She noted the Court has recognized an implied cause of action for rescission but not damages under a related statute.

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What the justices asked

Justice Thomas asked the FS side to respond to Saba Capital Master Fund's reading of Transamerica.

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Why it matters

The ruling could shape how investors challenge fee arrangements under the Investment Company Act. It may also clarify when courts infer a right to sue from a federal statute.

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What the Court decided

Section 47(b) of the Investment Company Act does not imply that private parties can sue to cancel, meaning legally undo, contracts that violate that law. The provision instead only guides what courts must do when such requests already come before them.

The Supreme Court reversed and remanded, reversing the Second Circuit's judgment that had affirmed the district court's grant of summary judgment.

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Official Court provenance

Official docket and case history · Official Supreme Court oral-argument detail page

Verified official opinions and orders

Title and summary sources

Revision history

  1. Revision 1 · Official Transcript ·

    Correction: Rewritten to the concise citizen-facing editorial standard.

  2. Revision 2 · Official Transcript ·

    Correction: Removed an unsupported statement that the Court had not ruled; the available source set did not establish that absence.

  3. Revision 3 · Official Transcript ·

    Correction: Corrected unsupported no-ruling language and clarified that the article's disposition summary is incomplete.

  4. Revision 4 · Post Opinion ·

    Correction: Added the holding and disposition from the verified official Court opinion.

  5. Revision 5 · Post Opinion ·

    Correction: Migrated to the dated official Court activity contract without model use.

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