Edwards v. First Trust Portfolios LP

CourtDistrict Court, N.D. Texas
DecidedJanuary 21, 2025
Docket3:23-cv-02239
StatusUnknown

This text of Edwards v. First Trust Portfolios LP (Edwards v. First Trust Portfolios LP) is published on Counsel Stack Legal Research, covering District Court, N.D. Texas primary law. Counsel Stack provides free access to over 12 million legal documents including statutes, case law, regulations, and constitutions.

Bluebook
Edwards v. First Trust Portfolios LP, (N.D. Tex. 2025).

Opinion

IN THE UNITED STATES DISTRICT COURT NORTHERN DISTRICT OF TEXAS DALLAS DIVISION

AARON EDWARDS, § § Plaintiff, § § V. § No. 3:23-cv-2239-BN § FIRST TRUST PORTFOLIOS L.P., § § Defendant. §

MEMORANDUM OPINION AND ORDER Defendant First Trust Portfolios L.P. (“First Trust”) has filed a motion for summary judgment. See Dkt. No. 56. Plaintiff Aaron Edwards filed a response, see Dkt. No. 69, and First Trust filed a reply, see Dkt. No. 72. For the reasons explained below, the Court grants in part and denies in part First Trust’s Motion for Summary Judgment [Dkt. No. 56]. Background Plaintiff Aaron Edwards filed this lawsuit against his former employer, Defendant First Trust, alleging that he was terminated in retaliation for engaging in purported whistleblowing activities. He asserts claims under the anti-retaliation and whistleblower protection provisions provide under the Sarbanes-Oxley Act (“SOX”), 18 U.S.C. § 1514A; the Dodd-Frank Wall Street Reform and Consumer Protection Act (“Dodd-Frank”), 15 U.S.C. § 78u-6; and the Consumer Financial Protection Act (“CFPA”), 12 U.S.C. § 5567. See Dkt. No. 1. First Trust is a registered securities broker-dealer specializing in the underwriting, trading, and distribution of various investment products. Edwards

began working for First Trust in 2019 as a wholesaler, and he reported to Steve Ritter. See id. Mr. Ritter, who served as Edwards’s direct supervisor, ultimately made the decision to terminate Edwards. See Dkt. No. 58 at 33. In October and November 2021, First Trust cited Edwards for compliance violations. See id. at 127-128. Edwards executed written warnings acknowledging

these violations and a statement of corrective action. See id. On March 8, 2022, Mr. Ritter sent an email to Edwards summarizing a discussion they had regarding work performance issues. See id. at 136-140. The email stated: If your percent of firm and rank continue to decline I am going to go a different route with someone else. I don’t want to do this but you have to deliver. Take this very seriously. Also during our discussion we went over Compliance very thoroughly and since you have had several compliance issues if anything else arises you will be let go. I don’t want you to leave but we can’t have people continue to make mistakes and put the firm at risk.

Id. at 136.

On May 3, 2022, First Trust cited Edwards for a third compliance violation, which involved purchasing an approximately $62 gift for one of his financial advisor clients to commemorate their child’s athletics accomplishment. See id. at 131. On May 5, 2022, Mr. Ritter sent an email to Andy Roggensack, First Trust’s President, stating that Edwards was a “compliance issue” and that he would “like to get rid of [him].” Dkt. No. 58 at 156. Edwards’s most recent violation implicated First Trust’s Gift Policy, which

stated that “[t]he First Trust Gift Rule on [financial] advisor[s] is $100 per year, however it is the firm’s policy to not give gifts because the First Trust year-end gift is usually right below the $100 threshold.” Id. at 133. Edwards alleges that, “[t]o get clarity on First Trust’s Gift Policy, [he] spoke with colleagues” and “learned that First Trust had a gift program in which First Trust only gives gifts to financial advisors at the end of the year who sold the most First

Trust products during that year.” Dkt. No. 71 at 5. And Edwards contends that this practice (the “Year-End Gift Policy”) constituted an illegal sales contest under Securities and Exchange Commission (“SEC”) and Financial Industry Regulatory Authority (“FINRA”) regulations. See id. at 5-6. On May 13, 2022, Edwards sent an email to Erik Jackson, First Trust’s Compliance Officer, expressing his concern that First Trust’s Year-End Gift Policy could be “(mis)construed” as an impermissible sales contest. Dkt. No. 58 at 340.

On May 19, 2022, Edwards and Mr. Jackson participated in a telephone call to discuss Edwards’s email, in which Mr. Jackson explained that First Trust’s Year-End Gift Policy did not run afoul of applicable regulations. See id. at 29. On the afternoon of May 20, 2022, Mr. Ritter sent an email to Edwards, which copied Mr. Jackson and Patricia Costello, head of First Trust’s human resources department. The email stated: Aaron, You still haven’t signed the write up form. We need to have a conversation Monday at the latest with all parties in this email. 10:30 Central time. Thank you.

Dkt. No. 71 at 23.

Later that same day, Edwards reported his concerns regarding First Trust’s Year-End Gift Policy to FINRA and the SEC via online submission forms. See Dkt. No. 58 at 354-366. On the morning of May 22, 2022, Ms. Costello sent Mr. Ritter an email with “Call” in the subject line, which purported to reference the conversation requested by Mr. Ritter in his earlier email to Edwards. See id. at 367. In the email, Ms. Costello identified areas to be covered during the call including “Compliance issues and why he has not signed the Written Warning” and “Performance Issues – sales numbers an issue.” Id. Ms. Costello also advised Mr. Ritter to be “legally prepared to present the material in the call to protect the company.” Id. Later that same day, Edwards responded to Mr. Ritter’s May 20, 2022 email with the same individuals copied. See Dkt. No. 71 at 22-23. In the email, Edwards shared his concerns that First Trust’s Year-End Gift Policy constituted an illegal sales contest and noted that he mentioned these concerns to Mr. Jackson in a prior email. See id. On May 23, 2022, First Trust formally terminated Edwards’s employment via a telephonic meeting that included Mr. Ritter, Mr. Jackson, Ms. Costello, and Mr. Roggensack. See Dkt. No. 58 at 110. After his termination, Edwards filed a wrongful termination complaint based on whistleblowing activity under SOX and the CFPA with the U.S. Department of Labor (“DOL”). See id. at 4-12.

The Occupational Safety and Health Administration (“OSHA”), the federal agency assigned to investigate retaliation claims by the DOL, investigated Edwards’s claims. See id. at 13-24. But, prior to OSHA issuing its findings, Edwards filed his complaint in this Court under SOX’s “kick out” provision. See Dkt. No. 71 at 33-34. Legal Standards

Under Federal Rule of Civil Procedure 56, summary judgment is proper “if the movant shows that there is no genuine dispute as to any material fact and the movant is entitled to judgment as a matter of law.” FED. R. CIV. P. 56(a). A factual “issue is material if its resolution could affect the outcome of the action.” Weeks Marine, Inc. v. Firemans Fund Ins. Co., 340 F.3d 233, 235 (5th Cir. 2003). “A factual dispute is ‘genuine,’ if the evidence is such that a reasonable [trier of fact] could return a verdict for the nonmoving party.” Crowe v. Henry, 115 F.3d 294, 296 (5th Cir. 1997).

If the moving party seeks summary judgment as to his opponent’s claims or defenses, “[t]he moving party bears the initial burden of identifying those portions of the pleadings and discovery in the record that it believes demonstrate the absence of a genuine issue of material fact, but is not required to negate elements of the nonmoving party’s case.” Lynch Props., Inc. v. Potomac Ins. Co., 140 F.3d 622, 625 (5th Cir. 1998).

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Edwards v. First Trust Portfolios LP, Counsel Stack Legal Research, https://law.counselstack.com/opinion/edwards-v-first-trust-portfolios-lp-txnd-2025.