Central Bank of Denver v. First Interstate Bank

E590646

United States Supreme Court case securities law case

Central Bank of Denver v. First Interstate Bank is a 1994 U.S. Supreme Court decision that held there is no private right of action for aiding and abetting under the federal securities fraud provisions, significantly limiting secondary liability in securities litigation.

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Statements (47)

Predicate	Object
instanceOf	United States Supreme Court case ⓘ securities law case ⓘ
branchOfLaw	United States corporate and securities law ⓘ
citation	511 U.S. 164 ⓘ
citationStyle	Central Bank of Denver, N.A. v. First Interstate Bank of Denver, N.A. NERFINISHED ⓘ
citedFor	Narrow interpretation of implied private rights of action in federal statutes ⓘ Proposition that aiding-and-abetting liability is not available to private plaintiffs under Section 10(b) ⓘ
country	United States of America ⓘ surface form: United States
court	Supreme Court of the United States ⓘ
decisionDate	1994 ⓘ
decisionType	5–4 decision ⓘ
dissentingJustices	David H. Souter NERFINISHED ⓘ Harry A. Blackmun NERFINISHED ⓘ John Paul Stevens NERFINISHED ⓘ Ruth Bader Ginsburg NERFINISHED ⓘ
effect	Eliminated private aiding-and-abetting claims under federal securities fraud provisions ⓘ Prompted increased attention to state-law aiding-and-abetting theories ⓘ Shifted focus of securities fraud litigation to primary violators ⓘ Significantly limited secondary liability in private securities litigation ⓘ
holding	Liability under Section 10(b) and Rule 10b-5 is limited to primary violators ⓘ Private plaintiffs cannot sue secondary actors solely for aiding and abetting securities fraud under federal law ⓘ There is no private right of action for aiding and abetting under Section 10(b) of the Securities Exchange Act of 1934 ⓘ
impactOnPractice	Reduced exposure of secondary actors such as banks, lawyers, and accountants to private federal securities fraud suits ⓘ
issue	Whether private plaintiffs may maintain an aiding-and-abetting action under Section 10(b) and Rule 10b-5 ⓘ
jurisdiction	United States federal law ⓘ
languageOfDecision	English ⓘ
legalArea	civil liability ⓘ federal securities law ⓘ securities fraud ⓘ
majorityJustices	Anthony M. Kennedy NERFINISHED ⓘ Antonin Scalia NERFINISHED ⓘ Clarence Thomas NERFINISHED ⓘ Sandra Day O’Connor NERFINISHED ⓘ William H. Rehnquist NERFINISHED ⓘ
majorityOpinionBy	Justice Anthony M. Kennedy NERFINISHED ⓘ
overruledOrLimited	Limited prior lower-court precedents recognizing aiding-and-abetting liability under Rule 10b-5 ⓘ
petitioner	Central Bank of Denver, N.A. NERFINISHED ⓘ
reasoning	Congress did not expressly create a private right of action for aiding and abetting in the text of Section 10(b) ⓘ Judicially implied causes of action should not be extended beyond the statute’s text and structure ⓘ
recognizedAs	leading case on the scope of private liability under Rule 10b-5 ⓘ
respondent	First Interstate Bank of Denver, N.A. NERFINISHED ⓘ
ruleInterpreted	SEC Rule 10b-5 NERFINISHED ⓘ
statuteInterpreted	Section 10(b) of the Securities Exchange Act of 1934 NERFINISHED ⓘ Securities Exchange Act of 1934 NERFINISHED ⓘ
subsequentDevelopment	Congress later addressed aiding-and-abetting liability for the SEC in the Private Securities Litigation Reform Act of 1995 ⓘ
yearArgued	1993 ⓘ
yearDecided	1994 ⓘ

Referenced by (1)

Full triples — surface form annotated when it differs from this entity's canonical label.

Section 10(b) of the Securities Exchange Act of 1934 → relatedCaseLaw → Central Bank of Denver v. First Interstate Bank ⓘ