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Administrative Law Judge (ALJ) Due Process Enforcement Actions

Mandelbaum Barrett PC

New York Cannabis Ruling: Businesses Can Raise Constitutional Challenges in OCM Administrative Hearings

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In a major legal win for New York cannabis licensees, Mandelbaum Barrett PC has secured a precedent-setting decision that strengthens the rights of businesses facing Office of Cannabis Management (OCM) enforcement actions....more

Foley & Lardner LLP

U.S. Supreme Court Rules SEC Must Try Securities Fraud Cases in Federal Jury Trials Rather than In-House Courts

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On June 27, 2024, the U.S. Supreme Court ruled that when the SEC seeks civil penalties against a defendant for securities fraud, the Seventh Amendment entitles the defendant to a jury trial. In a 6–3 decision, Chief Justice...more

UB Greensfelder LLP

The Seventh Amendment Right to Jury for Violations of the Commodity Exchange Act – Part II

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This is the second part of a two-part article discussing a defendant’s Seventh Amendment right to jury in an enforcement action by the Commodity Futures Trading Commission under the Commodity Exchange Act for civil monetary...more

UB Greensfelder LLP

The Seventh Amendment Right to Jury for Violations of the Commodity Exchange Act – Part I

UB Greensfelder LLP on

This is the first of a two-part article discussing a defendant’s Seventh Amendment right to jury in an enforcement action by the Commodity Futures Trading Commission under the Commodity Exchange Act for civil monetary...more

Burr & Forman

Tilton Tilts at SEC Enforcement, Again

Burr & Forman on

Having lost her initial suit (and appeal) to enjoin an SEC administrative enforcement action against her, the so-called “diva of distressed,” Lynn Tilton recently filed another lawsuit trying to halt her upcoming October 24...more

Quinn Emanuel

Business Litigation Report - August 2016

Quinn Emanuel on

Circuit Courts Align to Shield SEC Administrative Proceedings from Collateral Constitutional Attack - In response to the financial crisis of the late 2000s, Congress passed the Dodd-Frank Wall Street Reform and Consumer...more

Quinn Emanuel

August 2016: Circuit Courts Align to Shield SEC Administrative Proceedings from Collateral Constitutional Attack

Quinn Emanuel on

In response to the financial crisis of the late 2000s, Congress passed the Dodd-Frank Wall Street Reform and Consumer Protection Act (“Dodd-Frank”) in 2010. Previously the SEC could pursue civil penalties only against...more

Cadwalader, Wickersham & Taft LLP

The SEC Retains its House Advantage During Administrative Proceedings

Amendments to the Rules of Practice Do Little to Address Criticism that the Deck is Stacked - Facing pressure from industry practitioners and in the wake of constitutional challenges in multiple jurisdictions, the...more

Morgan Lewis

Federal Court Grants Full Civil Trial to FERC Enforcement Target

Morgan Lewis on

The decision will likely affect the strategies of enforcement targets in electric market manipulation cases. For the first time, a federal district judge has held that a review of a Federal Energy Regulatory Commission’s...more

Carlton Fields

Supreme Court Declines to Review Constitutionality of SEC In-House Court

Carlton Fields on

The SEC’s increased use of its own "home court" for enforcement proceedings has triggered constitutional challenges to SEC administrative proceedings (APs). See "Defendants Challenge SEC’s Increased Use of Administrative...more

Pierce Atwood LLP

New Amendments to SEC's Rules of Practice in Administrative Proceedings

Pierce Atwood LLP on

On July 13, 2016, the U.S. Securities and Exchange Commission (SEC) adopted several amendments to its Rules of Practice regarding administrative proceedings. The amendments address, among other things, the timing of...more

K&L Gates LLP

D.C. Circuit Appears Poised to Overturn First CFPB Enforcement Action to Reach the Court: Five Key Takeaways From Yesterday’s Oral...

K&L Gates LLP on

Major financial firms almost never litigate with their regulators. As a result, regulators often take aggressive enforcement positions with little fear of judicial scrutiny. That’s been especially true for the Consumer...more

Burr & Forman

SEC ALJ Slams Bebo; Summarily Denies ConLaw Challenge

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Laurie Bebo, CEO of Assisted Living Concepts, initially got some sympathetic words from the U.S. District Judge who felt constrained to turn away her constitutional challenge to the SEC’s administrative forum: The Court...more

Dorsey & Whitney LLP

DC Circuit: No Jurisdiction For Suits Re SEC Forum Selection Choice

Dorsey & Whitney LLP on

Suits challenging the SEC’s forum selection decisions continue to proliferate. As the trend has unfolded the Commission posted a memo on its website discussing the issue of forum selection and has proposed modifications to...more

Burr & Forman

D.C. Circuit Repulses Assault on the SEC’s Administrative Citadel

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The citadel of the SEC’s administrative forum has been under assault from several vectors over the past year or so, as a chorus of dissenting Respondents have mounted increasing challenges to its constitutional legitimacy, as...more

Burr & Forman

SEC ALJ Dismisses Case: Inside-Info Trades, But No Tipper Benefit

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An SEC administrative law judge (“ALJ”) found that former Wells Fargo trader Joseph Ruggieri traded on material nonpublic information tipped him by former analyst Greg Bolan, but dismissed the insider-trading charges against...more

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