Scott Allen Hume v. Financial Industry Regulatory Authority, Inc.

CourtDistrict Court, W.D. Washington
DecidedFebruary 3, 2026
Docket2:25-cv-01501
StatusUnknown

This text of Scott Allen Hume v. Financial Industry Regulatory Authority, Inc. (Scott Allen Hume v. Financial Industry Regulatory Authority, Inc.) is published on Counsel Stack Legal Research, covering District Court, W.D. Washington primary law. Counsel Stack provides free access to over 12 million legal documents including statutes, case law, regulations, and constitutions.

Bluebook
Scott Allen Hume v. Financial Industry Regulatory Authority, Inc., (W.D. Wash. 2026).

Opinion

5 UNITED STATES DISTRICT COURT FOR THE WESTERN DISTRICT OF WASHINGTON 6 AT SEATTLE 7 SCOTT ALLEN HUME, 8 CASE NO. 2:25-cv-01501-RSL 9 Plaintiff, v. 10 FINANCIAL INDUSTRY REGULATORY 11 ORDER TO SHOW CAUSE AUTHORITY, INC., 12

13 Defendant. 14

15 This matter comes before the Court on “Defendant FINRA’s Motion to Dismiss 16 Plaintiff Hume’s Complaint.” Dkt. 10. Plaintiff is a registered financial services and 17 investment adviser operating in the State of Washington. Defendant Financial Industry 18 Regulatory Authority (“FINRA”) is a quasi-governmental organization that regulates its 19 member brokerage firms, exchange markets, and financial advisors. Brokerage firms and 20 their representatives must register with FINRA if they intend to recommend and/or sell 21 securities. As part of its duties as a self-regulatory organization, FINRA maintains and 22 operates registration systems and publicly accessible databases regarding its members. 23 Plaintiff filed this lawsuit in Whatcom County Superior Court seeking an order 24 directing FINRA to expunge from its records and databases information related to a 25 customer complaint filed on or about January 11, 2024. Plaintiff seeks the equitable relief 26

ORDER TO SHOW CAUSE - 1 1 of expungement under the court’s inherent powers, guided by the considerations set forth 2 in FINRA Rules 2080 and 8312(g). Dkt. 1-2 at ¶¶ 73-89 (First Claim for Relief). He also 3 seeks a declaration under RCW 7.24.010 that references to the customer complaint should 4 be expunged, Dkt. 1-2 at ¶¶ 90-100 (Second Claim for Relief), and a permanent injunction 5 prohibiting FINRA from continuing publishing references to the complaint, Dkt. 1-2 at 6 ¶¶ 101-110 (Third Claim for Relief). FINRA removed the action to federal court on the 7 basis of both federal question and diversity jurisdiction. Dkt. 1. 8 FINRA filed this motion to dismiss under Rule 12(b)(6) of the Federal Rules of 9 Civil Procedure. The motion raises two main arguments. First, that the Securities 10 Exchange Act of 1934 (“the Exchange Act”) does not create a private right of action for 11 expungement or for any alleged violations of FINRA’s internal rules. And second, that the 12 remedies plaintiff seeks, namely expungement, declaratory relief, and permanent 13 injunction, are not available absent an underlying viable cause of action. 14 DISCUSSION 15 FINRA’s motion to dismiss has been fully briefed and is ripe for a decision. Before 16 addressing defendant’s arguments, however, this Court has an obligation to assure itself of 17 its jurisdiction, regardless whether either of the parties has raised the issue. See Ruhrgas 18 AG v. Marathon Oil Co., 526 U.S. 574, 583 (1999). “If the court determines at any time 19 that it lacks subject-matter jurisdiction, the court must dismiss the action.” Fed. R. Civ. P. 20 12(h)(3). Federal courts are courts of limited jurisdiction and are presumptively without 21 jurisdiction over civil actions: the burden of establishing the contrary rests upon the party 22 asserting jurisdiction. Kokkonen v. Guardian Life Ins. Co. of Am., 511 U.S. 375, 377 23 (1994). 24

25 26

ORDER TO SHOW CAUSE - 2 1 A. Federal Question Jurisdiction 2 The statute on which FINRA relies for federal question jurisdiction confers on the 3 district courts “original jurisdiction of all civil actions arising under the Constitution, laws, 4 or treaties of the United States.” 28 U.S.C. § 1331. “[A] case can ‘aris[e] under’ federal 5 law in two ways.” Gunn v. Minton, 568 U.S. 251, 257 (2013). Jurisdiction exists under 6 § 1331 if a “federal question is presented on the face of the plaintiff’s properly pleaded 7 complaint.” Retail Prop. Trust v. United Bhd. of Carpenters & Joiners of Am., 768 F.3d 8 938, 947 (9th Cir. 2014) (quoting Caterpillar Inc. v. Williams, 482 U.S. 386, 392 (1987)). 9 In addition, a state law cause of action may “arise under” federal law if federal law is 10 essential to the establishment of the claim, even if plaintiff has artfully pled the causes of 11 action to omit federal law references. 12 That is, federal jurisdiction over a state law claim will lie if a federal issue is: 13 (1) necessarily raised, (2) actually disputed, (3) substantial, and (4) capable 14 of resolution in federal court without disrupting the federal-state balance approved by Congress. Where all four of these requirements are met, [the 15 Supreme Court has] held, jurisdiction is proper because there is a serious 16 federal interest in claiming the advantages thought to be inherent in a federal forum, which can be vindicated without disrupting Congress's intended 17 division of labor between state and federal courts.

18 Gunn, 568 U.S. at 258 (internal quotation marks and citation omitted). 19 Plaintiff’s three causes of action were filed in state court and seek various forms of 20 equitable relief. No federal claims are expressly asserted, and federal jurisdiction is not 21 present on the face of the complaint. In its Notice of Removal, FINRA argues that the 22 Exchange Act provides an integrated and careful design for regulating the securities 23 industry, of which FINRA is a part, and that federal courts have exclusive jurisdiction over 24 25 26

ORDER TO SHOW CAUSE - 3 1 any claims arising under the Exchange Act. The Exchange Act contains a jurisdictional 2 provision that states, in relevant part: 3 The district courts of the United States and the United States courts of any 4 Territory or other place subject to the jurisdiction of the United States shall 5 have exclusive jurisdiction of violations of this chapter or the rules and regulations thereunder, and of all suits in equity and actions at law brought to 6 enforce any liability or duty created by this chapter or the rules and 7 regulations thereunder.

8 15 U.S.C.A. § 78aa(a) (Section 27(a)). The question, then, is whether plaintiff is seeking to 9 enforce a “duty created by [the Exchange Act] or the rules and regulations thereunder” 10 under the guise of state law labels and language. Id. 11 FINRA is burdened by a number of obligations and duties, including promulgating 12 rules to protect investors and the public, conducting disciplinary proceedings, 13 collecting/maintaining registration information about members, and administratively 14 reviewing disputes regarding the accuracy of reported information. Godfrey v. FINRA, No. 15 16-cv-2776-PSG (PJWx), 2016 WL 4224956, at *2 (C.D. Cal. 2016); FINRA Rule 16 8312(e). If plaintiff were seeking to enforce any of these duties, the exclusive jurisdiction 17 provision of Section 27(a) would apply. But plaintiff is not seeking administrative review 18 of a dispute regarding the accuracy of his registered information. Instead, he is pursuing a 19 judicial order directing that certain information be expunged, which he can then bring to 20 FINRA pursuant to FINRA Rule 2080(a), which provides: 21 Members or associated persons seeking to expunge information from the 22 [Central Registration Depository] system arising from disputes with 23 customers must obtain an order from a court of competent jurisdiction directing such expungement or confirming an arbitration award containing 24 expungement relief. 25 26

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Related

Caterpillar Inc. v. Williams
482 U.S. 386 (Supreme Court, 1987)
Kokkonen v. Guardian Life Insurance Co. of America
511 U.S. 375 (Supreme Court, 1994)
Ruhrgas Ag v. Marathon Oil Co.
526 U.S. 574 (Supreme Court, 1999)
Macken v. Jensen
333 F.3d 797 (Seventh Circuit, 2003)
Gunn v. Minton
133 S. Ct. 1059 (Supreme Court, 2013)

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Bluebook (online)
Scott Allen Hume v. Financial Industry Regulatory Authority, Inc., Counsel Stack Legal Research, https://law.counselstack.com/opinion/scott-allen-hume-v-financial-industry-regulatory-authority-inc-wawd-2026.