Barry Graham Armstrong v. Office of the Secretary of the Commonwealth Securities Division

CourtMassachusetts Superior Court
DecidedMay 16, 2022
Docket2084CV03041-BLS2
StatusPublished

This text of Barry Graham Armstrong v. Office of the Secretary of the Commonwealth Securities Division (Barry Graham Armstrong v. Office of the Secretary of the Commonwealth Securities Division) is published on Counsel Stack Legal Research, covering Massachusetts Superior Court primary law. Counsel Stack provides free access to over 12 million legal documents including statutes, case law, regulations, and constitutions.

Bluebook
Barry Graham Armstrong v. Office of the Secretary of the Commonwealth Securities Division, (Mass. Ct. App. 2022).

Opinion

SUPERIOR COURT

BARRY GRAHAM ARMSTRONG v. OFFICE OF THE SECRETARY OF THE COMMONWEALTH SECURITIES DIVISION

Docket: 2084CV03041-BLS2
Dates: April 25, 2022
Present: Kenneth W. Salinger Justice of the Superior Court
County: SUFFOLK, ss.
Keywords: MEMORANDUM AND ORDER ON CROSS-MOTIONS FOR JUDGMENT ON THE PLEADINGS

            The Securities Division of the Office of the Secretary of the Commonwealth (the “Division”) imposed sanctions on Barry Graham Armstrong, a registered broker-dealer of securities, for running a misleading radio advertisement. The ad urged listeners to call a toll-free number to get a free fact sheet about Alzheimer’s disease. Armstrong’s goal was to obtain contact information to promote his business of providing financial planning, investment advice, and broker-dealer services. When people called in response to the advertisement, Armstrong’s agents sent them a publicly available Alzheimer’s fact sheet together with material promoting Armstrong’s business.

            Mr. Armstrong contends that the Division’s decision is unlawful.

            The Court disagrees. It concludes that: (i) the decision did not violate Armstrong’s constitutional free speech rights because this bait advertising was misleading commercial speech; (ii) the regulation barring misleading advertisements is not unconstitutionally vague; (iii) the Division permissibly construed and properly applied Massachusetts regulations that govern conduct by broker-dealers; (iv) the Division did not violate Armstrong’s procedural due process rights; and (v) the decision is supported by substantial evidence and is neither arbitrary, capricious, nor an abuse of discretion.

            The Court will therefore deny Armstrong’s motion for judgment on the pleadings, allow the Division’s cross-motion for judgment on the pleadings,[1] and order that final judgment enter affirming the Division’s decision.

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[1] Under Superior Court Standing Order 1-96, ¶ 4, an opposition to a motion for judgment on the pleadings in a case seeking judicial review under G.L. c. 30A is deemed to include a cross-motion for judgment on the pleadings affirming the challenged administrative decision.

                                                            -1-

            1. Factual and Procedural Background. Mr. Armstrong is registered in Massachusetts as a broker-dealer agent for Securities America, Inc. (“SAI”) and as an investment adviser representative for Securities America Advisors. SAI is regulated by the Financial Industry Regulatory Authority (“FINRA”). Armstrong holds various FINRA licenses. He does business through a company called the Armstrong Advisory Group ( “AAG”).

            Armstrong hosts a radio show that addresses business and financial matters. It airs weekdays on stations throughout New England, including on WRKO in Massachusetts. AAG promotes itself primarily through radio advertisements that run during this and other radio programs.

            During July 2014, Armstrong ran a radio advertisement that offered information about Alzheimer’s disease, in order to elicit contact information from people so that Armstrong could send them information about AAG. This ad was aired at least 48 times in Massachusetts. It consisted of two parts.

            In the first part of the ad, Armstrong talked about Alzheimer’s disease, told listeners that “treatments for symptoms are available,” and encouraged listeners to call a toll-free number and request a “free fact sheet.” Armstrong did not identify himself or his business, and did not mention investments or financial advisory services. The text that Armstrong read during this part of the ad is as follows:

Did you know that Alzheimer’s disease is the most common form of dementia? And due to the growth of Alzheimer’s disease, dementia is taking an enormous toll on our society, our spouses, our children, and other family members. Alzheimer’s is not a normal part of aging. However, the greatest risk factor is increasing age.

Get the facts about Alzheimer’s disease with our free fact sheet, available now. Call us today at 866-810-6422 to learn more about Alzheimer’s disease and dementia. Alzheimer’s has no current cure, but treatments for symptoms are available. If you or a loved one has been diagnosed with Alzheimer’s or a related dementia, you’re not alone.

Learn what resources there are to support those affected by the disease. That number again is 866-810-6422.

At that point, a different voice read disclaimer language prepared by SAI; this text was read very quickly. The disclaimer portion of the ad was as follows:

                                                            -2-

Securities offered through Securities America, Inc., member FINRA/SIPC and advisory services offered through Securities America Advisors, Inc., Barry Armstrong, representative. Armstrong Advisory Group and the Securities America Companies are unaffiliated.

Calls to the number read in this advertisement were answered by a call center that had been retained by AAG. The call center employees would answer each call by saying “Armstrong Advisory Group, Securities America, how may I help you?” If the caller asked for the Alzheimer’s fact sheet, the employee would ask for and record the caller’s name, mailing address, email address, and telephone number, and the fact that they called in response to the Alzheimer’s advertisement. The employee would enter that information into a database and immediately email it to AAG, Armstrong’s company.

            AAG then followed up by mailing to each person who called in response to the Alzheimer’s advertisement a packet containing three things:

o a one-page letter from Barry Armstrong offering financial-planning and investment-management services through AAG, as well as a “free 60-minute consultation with a financial planner;”

o a four-page memorandum from “Cushing & Dolan, P.C., Attorneys at Law” about using Personal Care Contracts to transfer money from a parent to their child without those payments being subject to Medicaid’s five-year look back period—at the bottom of each page, this memo said, “For a free, no obligation financial consultation, contact Armstrong Advisory Group at (800) 393-4001;” and

            o an eight-page Alzheimer’s Disease Fact Sheet that was prepared and published by, and            available for free from, the Alzheimer’s Disease Education & Referral Center of the National Institute on Aging.

Almost eighty Massachusetts residents called in response to Armstrong’s Alzheimer’s ad and received these packets. An AAG employee then called each of these people, and asked whether they would like to set up an appointment with the Armstrong Advisory Group or with an elder law attorney. Two of them agreed to meet with AAG.

            The Division’s Enforcement Section filed an administrative complaint against Armstrong in July 2015. It conducted an evidentiary hearing in this matter in April 2018. The hearing officer issued a recommended decision in June 2020, and the Division adopted it as its Final Order in early December 2020.

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Bluebook (online)
Barry Graham Armstrong v. Office of the Secretary of the Commonwealth Securities Division, Counsel Stack Legal Research, https://law.counselstack.com/opinion/barry-graham-armstrong-v-office-of-the-secretary-of-the-commonwealth-masssuperct-2022.