Raymond J. Lucia Companies, Inc. v. Securities & Exchange Commission

ROGERS, Circuit Judge:

Raymond J. Lucia and Raymond J. Lucia Companies, Inc., petition for review of the decision of the Securities and Exchange Commission imposing sanctions for violations of the Investment Advisers Act of 1940 and the rule against misleading advertising. Upon granting a petition for review of an initial decision by an administrative law judge (“ALJ”), the Commission rejected petitioners’ challenges to the liability and sanctions determinations and petitioners’ argument that the administrative hearing was an unconstitutional procedure because the administrative law judge who…