Cato Institute v. United States Securities and Exchange Commission

CourtDistrict Court, District of Columbia
DecidedFebruary 10, 2020
DocketCivil Action No. 2019-0047
StatusPublished

This text of Cato Institute v. United States Securities and Exchange Commission (Cato Institute v. United States Securities and Exchange Commission) is published on Counsel Stack Legal Research, covering District Court, District of Columbia primary law. Counsel Stack provides free access to over 12 million legal documents including statutes, case law, regulations, and constitutions.

Bluebook
Cato Institute v. United States Securities and Exchange Commission, (D.D.C. 2020).

Opinion

UNITED STATES DISTRICT COURT FOR THE DISTRICT OF COLUMBIA ____________________________________ ) CATO INSTITUTE ) ) Plaintiff, ) ) v. ) Civil Action No. 19-0047 (ABJ) ) UNITED STATES ) SECURITIES AND ) EXCHANGE COMMISSION, et al., ) ) Defendants. ) ____________________________________)

MEMORANDUM OPINION

Plaintiff Cato Institute (“Cato” or “plaintiff”) has brought this action against the United

States Securities and Exchange Commission (“SEC”); Jay Clayton, in his official capacity as

Chairman of the SEC; and Vanessa A. Countryman, in her official capacity as Secretary of the

SEC. Plaintiff seeks to challenge the SEC’s policy of including “no-deny” provisions in its consent

judgments in civil or administrative proceedings. Am. Compl. [Dkt. # 11]. These provisions

preclude a settling party from publicly denying the allegations in a complaint resolved by consent.

Id. ¶ 1. Plaintiff claims that the agency’s policy of silencing the subjects of its investigations

violates the First Amendment of the Constitution. Id. ¶ 73. But the Cato Institute was not the

subject of any investigation, and it is not party to any consent judgment; it brings this action

alleging that its ability to publish and promote the parties’ stories has been compromised.

Defendants moved to dismiss the complaint on the grounds that plaintiff lacks standing to

bring the case and that it has failed to state a claim upon which relief can be granted. Defs.’ Mot.

to Dismiss Pl.’s Am. Compl. [Dkt. # 12] (“Defs.’ Mot.”). Because the Court finds that plaintiff lacks standing to challenge the SEC’s “no-deny” policy, the Court will grant defendants’ motion

to dismiss for lack of subject matter jurisdiction. Because the Court has no power to hear the case,

this opinion does not address the merits of the dispute, and it should not be read to express any

view about the wisdom of the policy.

BACKGROUND

In 1972, the SEC promulgated a regulation adopting a formal policy that it would not

“permit a defendant or respondent to consent to a judgment or order that imposes a sanction while

denying the allegations in the complaint or order for proceedings.” 17 C.F.R. § 202.5(e) (1972).

The agency explained that “in any civil lawsuit brought by [the SEC] or in any administrative

proceeding of an accusatory nature pending before it, it is important to avoid creating, or permitting

to be created, an impression that a decree is being entered or a sanction imposed, when the

conducted alleged did not, in fact, occur.” Id.

Plaintiff alleges that the SEC has carried out this policy by requiring that an express “no-

deny” provision be included in the consent judgment as a condition of settling any civil or

administrative action brought by the agency. Am. Compl. ¶ 16. The provision prohibits settling

defendants from “publicly asserting that any of the SEC’s allegations are untrue or otherwise lack

a factual basis.” Id. ¶ 21. And, according to the complaint, since 2002, the SEC has had a steady

settlement rate of approximately ninety-eight percent. Id. ¶ 26, citing Priyah Kaul, Admit or Deny:

A Call for Reform of the SEC’s ‘Neither-Admit-Nor-Deny’ Policy, 48 U. MICH. J. L. REFOR. 535,

536 (2015).

The events that form the basis of plaintiff’s suit began in 2018, when Cato’s Vice President

for Criminal Justice, Clark Neily, “privately received a copy of a manuscript written by an author

who claimed he had been the victim of prosecutorial overreach at the hands of officials at the

SEC.” Am. Compl. ¶ 31. The amended complaint states that the manuscript “describes a long and

2 expensive battle at the end of which the author . . . ultimately [settled and] admitted to engaging

in certain limited conduct in order to avoid crippling litigation expenses.” Id. ¶ 32.

The “no-deny” provision contained in the author’s settlement agreement provides:

Defendant understands and agrees to comply with the Commission’s policy “not to permit a defendant or respondent to consent to a judgment or order that imposes a sanction while denying the allegation in the complaint or order for proceedings.” 17 C.F.R. § 202.5. In compliance with this policy, Defendant agrees not to take any action or to make or cause to be made any public statement denying, directly or indirectly, any allegation in the complaint or creating the impression that the complaint is without factual basis. Defendant may testify truthfully about any matter under oath in connection with a legal or administrative proceeding, whether or not under subpoena . . . . If Defendant breaches this agreement, the Commission may petition the Court to vacate the Final Judgment and restore this action to its active docket. 1

Id. ¶ 37. The author asked Neily to assess the validity of the policy and the prospects for

challenging or being relieved from the no-deny provision, so that he could publish his manuscript.

Id. ¶ 31. In Neily’s view, publishing the author’s manuscript would “advance important public-

policy goals of the Cato Institute”; the document addresses issues that have already been the

subject of the organization’s work, including “prosecutorial discretion, routine over-charging, and

the danger of coercive settlements or plea bargains.” Id. ¶ 33. In 2018, Cato entered into a contract

with the author to publish his manuscript. 2 Id. ¶ 34.

Plaintiff alleges that it has taken substantial steps towards publication, but that it “cannot”

complete the process because the author is bound by the “no-deny” provision contained in his

1 The provision goes on: “[n]othing in this paragraph affects Defendant’s: (i) testimonial obligations, or (ii) right to take legal or factual positions in litigation or other legal proceedings in which the [SEC] is not a party including, but not limited to, legal proceedings arising out of the matters filed in the bankruptcy court.” Am. Compl. ¶ 37.

2 The complaint does not allege that the author or the contract placed any restrictions on the Cato Institute’s right to publish the manuscript. 3 settlement agreement. Am. Compl. ¶¶ 35–36. Plaintiff claims it “cannot exercise what would

otherwise be its contractual right to publish and promote the SEC manuscript”; “[b]ut for the gag

order,” it “would immediately complete its editorial process and publish the SEC manuscript.”

Id. ¶¶ 39–40. Plaintiff says it would also “undertake promotional activities relating to the

book . . . [such as] writing about the book in newspapers and on the internet as well as sponsoring

promotional events.” Id. ¶ 41. According to the complaint, the publication of the author’s

manuscript and the public promotion of the book would be a violation of the author’s settlement

agreement with the SEC. 3 Id.

Plaintiff also alleges that there are other individuals who signed “no-deny” provisions as a

condition of settling enforcement actions who are willing to speak out against the SEC’s policy.

Am. Compl. ¶ 42. They contacted Cato and Vice President Neily in the wake of this lawsuit and

voiced an interest in publicly contesting the SEC’s allegations in their cases. Id. Plaintiff alleges:

But for the gag orders in place, these individuals would also be willing to permit the Cato Institute to publicly tell their stories or portions of their stories, including by repeating relevant details or quotations in essays, op- eds, or blog posts.

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