McDaniel, et al v. Wells Fargo Investments, LLC, et al, No. 11-17017 (9th Cir. 2013)
Annotate this CasePlaintiffs, former employees of brokerage firms, filed four class actions challenging California's forced-patronage statute, section 450(a) of the California Labor Code. At issue was whether federal securities law preempted the enforcement of California's forced-patronage statute against brokerage houses that forbid their employees from opening outside trading accounts. The court affirmed the judgment and concluded that the district court correctly determined that the Securities Exchange Act of 1934, 15 U.S.C. 78o(g), and related self-regulatory organizations (SROs) rules preempted plaintiffs' forced-patronage suits.
Court Description: Securities Law. The panel affirmed the district courts’ dismissals of four class actions challenging the policies of brokerage firms that forbid their employees from opening outside trading accounts. The panel held that the district courts correctly determined that the federal Securities Exchange Act, and related “self-regulatory organizations” rules, preempt the en fo rc em en t of California’s forced-p at ro nage statute—section 450(a) of the California Labor Code—against brokerage houses that forbid their employees from opening outside trading accounts.
Some case metadata and case summaries were written with the help of AI, which can produce inaccuracies. You should read the full case before relying on it for legal research purposes.
This site is protected by reCAPTCHA and the Google Privacy Policy and Terms of Service apply.