In 2014, in the case of United States v. Newman, the United States Court of Appeals for the Second Circuit cited the Supreme Court's decision in Dirks, and ruled that in order for a "tippee" (a person who has received insider information from an insider and has used that information) to be guilty of insider trading, the tippee must have been aware not only that the information was insider information, but must also have been aware that the insider released the information for an improper purpose (such as a personal benefit). The Court concluded that the insider's breach of a fiduciary duty not to release confidential information—in the absence of an improper purpose on the part of the insider—is not enough for criminal liability to be imposed on the either the insider or the tippee.[6]