Securities and Exchange Commission v. Jacobson

CourtDistrict Court, E.D. Louisiana
DecidedApril 7, 2025
Docket2:23-cv-05650
StatusUnknown

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

Bluebook
Securities and Exchange Commission v. Jacobson, (E.D. La. 2025).

Opinion

UNITED STATES DISTRICT COURT EASTERN DISTRICT OF LOUISIANA

SECURITIES AND EXCHANGE COMMISSION CIVIL ACTION

VERSUS NO: 23-5650

STEVEN JACOBSON, ET AL. SECTION: “H”

ORDER AND REASONS Before the Court is Defendant Steven Jacobson’s Motion in Limine to Exclude the Testimony and Opinions of Eugene P. Canjels, Ph.D. (Doc. 47); Plaintiff Security and Exchange Commission’s Motion in Limine to Exclude Export Reports and Opinions of Dr. David A. Lesmond (Doc. 48); and Defendant Steven Jacobson’s Motion for Summary Judgment (Doc. 49). Oral argument on the Motions were held on March 27, 2025. For the following reasons, Defendant’s Motion in Limine to Exclude the Testimony and Opinions of Eugene P. Canjels, Ph.D. is DENIED; Plaintiff Security and Exchange Commission’s Motion in Limine to Exclude Export Reports and Opinions of Dr. David A. Lesmond is GRANTED; and Defendant’s Motion for Summary Judgment is DENIED. BACKGROUND On September 29, 2023, the United States Securities and Exchange Commission (“SEC”) filed this civil suit, alleging various violations of the Securities Exchange Act of 1934 (“Exchange Act”)1, Securities Act of 1933

1 15 U.S.C. § 78j(b). (“Securities Act”)2, and Investment Advisers Act of 1940 (“Advisers Act”)3 by Defendants Steven Jacobson, his mother Marian Jacobson, and Adviser Resource Council (“ARC”).4 ARC is a registered investment adviser where Jacobson was formerly employed as a Louisiana-based investment adviser representative (“IAR”). In its Complaint, the SEC alleges that Defendant engaged in a cherry- picking scheme from July 31, 2020 to October 1, 2020 (the “Relevant Period”) in which he disproportionately allocated option trades with positive returns between the time of the trade and the time of the allocation (“first-day returns”) to his personal account, to an account in his mother’s name, and 3 other favored client accounts (collectively, the “Favored Accounts”), while disproportionately allocating option trades with negative first-day returns to other clients (collectively, the “Disfavored Accounts”), which sustained substantial first-day losses as a result.5 The SEC alleges that Defendant would place option trades in the firm’s block account at TD Ameritrade (“TDA”) and would wait to allocate them until after he had an opportunity to observe a trade’s intraday performance. The SEC alleges this scheme resulted in ill-gotten gains of approximately $207,902 across the Favored Accounts. Defendant Jacobson now moves this Court to exclude the testimony of Plaintiff SEC’s expert, Eugene P. Canjels, Ph.D. and grant summary judgment in his favor. Plaintiff opposes.6 Additionally, Plaintiff moves this Court to

2 15 U.S.C. § 77q(a)(1). 3 15 U.S.C. § 80b-6(1), (2). . 4 Marian Jacobson is named as a Relief Defendant in the Complaint. Doc. 1 at 4. On February 16, 2024, the Court approved a consent judgment between Plaintiff and Defendant ARC, which resolved all civil claims against ARC in this case. Doc 17. As such, “Defendant” stands for Steven Jacobson throughout. 5 Plaintiff alleges that during the Relevant Period, Defendant executed 256 option trades from which he made 850 allocations. Doc. 47-4 ¶ 30. 6 Docs. 52, 53. exclude the testimony of Defendant Jacobson’s expert, Dr. David A. Lesmond. Defendant opposes.7 The Court will consider these motions in turn.

LEGAL STANDARD I. Summary Judgement Summary judgment is appropriate “if the pleadings, depositions, answers to interrogatories, and admissions on file, together with affidavits, if any, show that there is no genuine issue as to any material fact and that the moving party is entitled to a judgment as a matter of law.”8 A genuine issue of fact exists only “if the evidence is such that a reasonable jury could return a verdict for the nonmoving party.”9 In determining whether the movant is entitled to summary judgment, the Court views facts in the light most favorable to the non-movant and draws all reasonable inferences in his favor.10 “If the moving party meets the initial burden of showing that there is no genuine issue of material fact, the burden shifts to the non-moving party to produce evidence or designate specific facts showing the existence of a genuine issue for trial.”11 Summary judgment is appropriate if the non-movant “fails to make a showing sufficient to establish the existence of an element essential to that party’s case.”12 “In response to a properly supported motion for summary judgment, the non-movant must identify specific evidence in the record and articulate the manner in which that evidence supports that party’s claim, and such evidence must be sufficient to sustain a finding in favor of the non-movant on all issues as to which the non-

7 Doc. 54. 8 FED. R. CIV. P. 56(c). 9 Anderson v. Liberty Lobby, Inc., 477 U.S. 242, 248 (1986). 10 Coleman v. Houston Indep. Sch. Dist., 113 F.3d 528 (5th Cir. 1997). 11 Engstrom v. First Nat’l Bank of Eagle Lake, 47 F.3d 1459, 1462 (5th Cir. 1995). 12 Celotex Corp. v. Catrett, 477 U.S. 317, 324 (1986). movant would bear the burden of proof at trial.”13 “We do not . . . in the absence of any proof, assume that the nonmoving party could or would prove the necessary facts.”14 Additionally, “[t]he mere argued existence of a factual dispute will not defeat an otherwise properly supported motion.”15 II. Expert Testimony The admissibility of expert testimony is governed by Federal Rule of Evidence 702, which provides as follows: A witness who is qualified as an expert by knowledge, skill, experience, training, or education may testify in the form of an opinion or otherwise if the proponent demonstrates to the court that it is more likely than not that: (a) the expert’s scientific, technical, or other specialized knowledge will help the trier of fact to understand the evidence or to determine a fact in issue; (b) the testimony is based on sufficient facts or data; (c) the testimony is the product of reliable principles and methods; and (d) the expert’s opinion reflects a reliable application of the principles and methods to the facts of the case. The current version of Rule 702 reflects the Supreme Court’s decisions in Daubert v. Merrell Dow Pharms., Inc.,16 and Kumho Tire Co. v. Carmichael17 as well as the 2023 amendments.18 The threshold inquiry is whether the expert possesses the requisite qualifications to render opinion on a particular subject

13 John v. Deep E. Tex. Reg. Narcotics Trafficking Task Force, 379 F.3d 293, 301 (5th Cir. 2004) (internal citations omitted). 14 Badon v. R J R Nabisco, Inc., 224 F.3d 382, 394 (5th Cir. 2000) (quoting Little v. Liquid Air Corp., 37 F.3d 1069, 1075 (5th Cir. 1994)). 15 Boudreaux v. Banctec, Inc., 366 F. Supp. 2d 425, 430 (E.D. La. 2005). 16 509 U.S. 579

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