Securities & Exchange Commission v. Charles Zandford
Court of Appeals for the Fourth Circuit
1Opinion of the Court
OPINION
WILKINSON, Chief Judge:
Defendant Charles Zandford was convicted of thirteen counts of wire fraud for stealing from two of his investment clients. The Securities and Exchange Commission subsequently filed this civil action against Zandford under § 17(a) of the Securities Act of 1933, § 10(b) of the Securities Exchange Act of 1934, and the SEC’s Rule 10b-5. The district court granted the SEC’s motion for summary judgment. Zandford now appeals. We hold that the federal securities laws do not reach every claim for the theft or conversion of a security from a brokerage account. Because…
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