Where the plaintiff could not avoid the Securities Litigation Uniform Standards Act by failing to plead scienter and basing her claims on state law contract and fiduciary duty principles, the lower court order was affirmed.The 7th U.S. Circuit Court of Appeals affirmed a decision by U.S. District Judge John W. Darrah.JPMorgan Chase Bank offered to manage the securities in clients’ portfolios. Its affiliates sponsor mutual funds in which those funds could be placed. Patricia Holtz, on behalf of a class of other …