LISA WRIGHT v. OPPENHEIMER & COMPANY, INC.

CourtCourt of Appeals of Georgia
DecidedMay 6, 2025
DocketA25A0195
StatusPublished

This text of LISA WRIGHT v. OPPENHEIMER & COMPANY, INC. (LISA WRIGHT v. OPPENHEIMER & COMPANY, INC.) is published on Counsel Stack Legal Research, covering Court of Appeals of Georgia primary law. Counsel Stack provides free access to over 12 million legal documents including statutes, case law, regulations, and constitutions.

Bluebook
LISA WRIGHT v. OPPENHEIMER & COMPANY, INC., (Ga. Ct. App. 2025).

Opinion

FOURTH DIVISION MERCIER, C. J., DILLARD, P. J., and LAND, J.

NOTICE: Motions for reconsideration must be physically received in our clerk’s office within ten days of the date of decision to be deemed timely filed. https://www.gaappeals.us/rules

May 6, 2025

In the Court of Appeals of Georgia A25A0182. KEARNEY et al v. OPPENHEIMER & COMPANY, INC. et al. A25A0195. WRIGHT et al. v. OPPENHEIMER & COMPANY, INC. et al.

DILLARD, Presiding Judge.

In the two cases underlying these consolidated appeals, John Kearny and Lisa

Wright separately—along with many other plaintiffs—sued Oppenheimer &

Company, Inc., Ann Greene, and Gordon Morse1 for violating Georgia’s Racketeer

Influenced and Corrupt Organizations Act (“RICO”), conspiracy to violate RICO,

and negligence per se. The appellants in both cases2 appeal the trial court’s orders

1 Except when Greene or Morse are referenced individually, they and Oppenheimer & Company, Inc., will be referred to collectively as “Oppenheimer.” 2 The appellants in Case No. A25A0182 are Georgia residents (collectively, the “Kearny appellants”) and those in Case No. A250195 are North Carolina residents granting Oppenheimer’s motions to dismiss their complaints for failure to state a

claim. They argue the trial court erred by (1) applying an incorrect standard in

determining their complaints did not adequately plead the element of proximate cause

as to their RICO claims; (2) concluding that regulations enacted by the Georgia

Securities Commissioner could not be the basis for a claim of negligence per se; and

(3) ruling that the Wright appellants—all North Carolina citizens—could not sue

Oppenheimer under Georgia’s RICO statute. For the following reasons, we affirm in

both cases.3

(collectively, the “Wright appellants”). Because the lawsuits are the same in all material respects, they were placed on a “parallel track” before the same judge, but not consolidated into a single case. The trial court issued separate, but substantially similar, orders on the same day dismissing the complaints. When referencing both cases, the Wright and Kearny appellants will be collectively referred to as “the appellants.” 3 Oral argument was held in these consolidated appeals on December 3, 2024, and is archived. See Court of Appeals of the State of Georgia, Oral Argument, Case Nos. A25A0182, A25A0195 (Dec. 3, 2024), available at https://vimeo.com/1036761617. 2 Viewed de novo in the light most favorable to the appellants,4 the complaints

alleged the following.5 Oppenheimer is a New York corporation that describes itself

as “a leading global full-service brokerage and investment bank.” And at all relevant

times, Oppenheimer engaged in business as a broker-dealer under OCGA § 10-5-306

and maintained an office in Atlanta. From 2012 until 2016, Morse was Oppenheimer’s

Atlanta branch manager, and he supervised John Woods, one of the salesmen. During

the same period, Greene was Oppenheimer’s “branch administrative manager” in its

Atlanta office, and she was also responsible for supervising Woods, as well as other

employees.

4 See, e.g., Campbell v. Cirrus Educ., Inc., 355 Ga. App. 637, 638 (845 SE2d 384) (2020) (“[O]n appeal, this Court conducts a de novo review of a trial court’s ruling on a motion to dismiss. In doing so, our role is to determine whether the allegations of the complaint, when construed in the light most favorable to the plaintiff, and with all doubts resolved in the plaintiff’s favor, disclose with certainty that the plaintiff would not be entitled to relief under any state of provable facts . . . .”). 5 The facts alleged in both complaints are identical in all material respects. For the sake of clarity and ease of reference, the factual background described in this opinion is gleaned from the complaint filed in Case No. A25A0195. 6 See OCGA § 10-5-30 (a) (“It is unlawful for a person to transact business in this state as a broker-dealer unless the person is registered under this chapter as a broker-dealer or is exempt from registration as a broker-dealer under subsection (b) or (d) of this Code section.”). 3 Given its status as a broker-dealer, Oppenheimer was required to file an

accurate and truthful Uniform Termination Notice for Securities Industry Regulations

(“U-5 Form”), which reports the termination of a salesman and the reasons for his

or her firing.7 Oppenheimer also had a continuing obligation to amend and update its

initial U-5 Form filing to note, inter alia, internal investigations or civil litigation

involving investment-related statutes that took place while Morse, Greene, Woods,

and others were associated with the company. Indeed, the U-5 Form is often the first

indication that the Georgia Securities Commission (“GSC”) receives regarding

potential misconduct by members of the securities industry. And GSC rules also

imposed on Oppenheimer, Morse, and Greene the duty to “exercise diligent

supervision over activities of its agents and associated persons.” Indeed, under GSC

rules, Oppenheimer, Morse, and Greene were required to supervise Woods’s

7 See Ga. Comp. R. & Regs. 590-4-5-.03 (3) (“No broker-dealer or issuer shall employ any agent who is not registered as required by the Act, and each such broker-dealer or issuer shall promptly notify the Commissioner of its termination of such agent’s employment. The registration of such agent shall automatically be terminated from the time of termination of employment. Said notification may be accomplished by filing the necessary documents with the CRD. If the agent is not registered with the CRD, notification shall be accomplished by filing a Uniform Termination Notice for Securities Industry Registration (U-5 Form) with the Commissioner.”). 4 activities to ensure they did not violate securities law, as well as to “approve all

outside investment and securities business activities of each [Oppenheimer] agent

prior to the agent engaging in such activities”

In September 2008, Oppenheimer’s office of legal counsel in New York was

served with a subpoena issued in a civil proceeding then pending in Fulton County,

Georgia, styled Lisa Walsh et al. v. John Woods et al. At that point, Woods had not

informed Oppenheimer about this lawsuit, which violated the company’s rules, as well

as securities-industry rules. In that case, the plaintiffs alleged they met with Woods

at Oppenheimer’s Atlanta office to discuss possible investment opportunities, and

Woods fraudulently induced them to collectively invest $964,000 in unapproved,

illicit programs by promising a 12 percent return on their investments.

Regardless of its ultimate disposition, the Walsh lawsuit provided Oppenheimer

with “actual notice” that Woods (1) had been sued in an investment-related case; (2)

was engaged in multiple undisclosed and unapproved outside business activities in

violation of securities laws and regulations; (3) failed to notify Oppenheimer of the

lawsuit; and (4) engaged in private securities transactions (those not approved by

Oppenheimer) in violation of securities laws and regulations. And as of the time those

5 lawsuits were initiated, Oppenheimer still had not disclosed to securities regulators

that Woods—its registered agent—was named as a defendant in the Walsh lawsuit.

Sometime in 2008, while working as a broker in good standing at Oppenheimer

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