Central Bank of Denver v. First Interstate Bank
E590646
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.
All labels observed (1)
| Label | Occurrences |
|---|---|
| Central Bank of Denver v. First Interstate Bank canonical | 1 |
How this entity was disambiguated
This entity first appeared as the object of triple T6409124 — resolving that mention is where its identity was fixed. The disambiguator weighed these candidate entities and picked the highlighted one (or “None”, minting a new entity). This is how homonymy is resolved: the same surface form can point to different entities.
NED1
Entity disambiguation (via context triple)
gpt-5-mini-2025-08-07
Target entity: Central Bank of Denver v. First Interstate Bank Context triple: [Section 10(b) of the Securities Exchange Act of 1934, relatedCaseLaw, Central Bank of Denver v. First Interstate Bank]
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A.
Northeast Bancorp, Inc. v. Board of Governors
Northeast Bancorp, Inc. v. Board of Governors is a 1985 U.S. Supreme Court case that addressed whether regional interstate banking compacts among states violated the Constitution’s Compact Clause and related federal banking laws.
-
B.
FDIC v. Meyer
FDIC v. Meyer is a 1994 U.S. Supreme Court decision that clarified the limits of suing the federal government and its agencies for constitutional violations under the doctrine of sovereign immunity.
-
C.
United States Trust Co. v. New Jersey
United States Trust Co. v. New Jersey is a 1977 U.S. Supreme Court case that clarified the limits of state power to impair public contracts under the Constitution’s Contract Clause.
-
D.
Meritor Savings Bank v. Vinson
Meritor Savings Bank v. Vinson is a 1986 U.S. Supreme Court case that first recognized workplace sexual harassment as a form of sex discrimination actionable under Title VII.
-
E.
Pollock v. Farmers' Loan & Trust Co.
Pollock v. Farmers' Loan & Trust Co. was an 1895 U.S. Supreme Court case that struck down a federal income tax as unconstitutional, prompting the later adoption of the Sixteenth Amendment to authorize such taxes.
- F. None of above. chosen
- G. Unsure - the case is ambiguous/there is not enough information to decide.
NED2
Entity disambiguation (via description)
gpt-5-mini-2025-08-07
Target entity: Central Bank of Denver v. First Interstate Bank Target entity description: 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.
-
A.
Northeast Bancorp, Inc. v. Board of Governors
Northeast Bancorp, Inc. v. Board of Governors is a 1985 U.S. Supreme Court case that addressed whether regional interstate banking compacts among states violated the Constitution’s Compact Clause and related federal banking laws.
-
B.
FDIC v. Meyer
FDIC v. Meyer is a 1994 U.S. Supreme Court decision that clarified the limits of suing the federal government and its agencies for constitutional violations under the doctrine of sovereign immunity.
-
C.
United States Trust Co. v. New Jersey
United States Trust Co. v. New Jersey is a 1977 U.S. Supreme Court case that clarified the limits of state power to impair public contracts under the Constitution’s Contract Clause.
-
D.
Meritor Savings Bank v. Vinson
Meritor Savings Bank v. Vinson is a 1986 U.S. Supreme Court case that first recognized workplace sexual harassment as a form of sex discrimination actionable under Title VII.
-
E.
Pollock v. Farmers' Loan & Trust Co.
Pollock v. Farmers' Loan & Trust Co. was an 1895 U.S. Supreme Court case that struck down a federal income tax as unconstitutional, prompting the later adoption of the Sixteenth Amendment to authorize such taxes.
- F. None of above. chosen
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 ⓘ |
How these facts were elicited
The pipeline generated the facts above by prompting gpt-5.1 with this entity's name + description and the instruction below.
Instruction
You are a knowledge base construction expert. Given a subject entity and a description of it, return factual statements that you know for the subject as a JSON list of dictionaries(triples), where keys must be "subject", "predicate" and "object". The number of facts may be very high, between 25 to 50 or more, for very popular subjects. For less popular subjects, the number of facts can be very low, like 5 or 10. # Requirements - If you don't know the subject at all, return an empty list. - If the subject is not a named entity, return an empty list. - Include at least one triple where predicate is "instanceOf". - Do not get too wordy. - Separate several objects into multiple triples with one object.
Input
Subject: Central Bank of Denver v. First Interstate Bank Description of subject: 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.
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
ⓘ