United States DC Circuit

The Commission erred in imposing a cease-and-desist order, which prohibits petitioner from committing or causing any future violations of the All Holders Rule, without a rational explanation of why such a sanction was appropriate under the Commission's own standards.

Appellate Information

• Argued 03/12/2004
• Decided 04/12/2004
• Published 04/09/2004

Judges

• Before:  EDWARDS and HENDERSON, Circuit Judges, and WILLIAMS, Senior Circuit Judge.

Court

• United States DC Circuit

Counsel

• For Appellant:
  
• Charles R. Mills argued the cause for petitioner.   With him on the briefs was Dylan B. Carp.  Paul Gonson entered an appearance.


• For Appellees:
  
• Giovanni P. Prezioso, General Counsel, Securities and Exchange Commission, argued the cause for respondent.   With him on the brief were Eric Summergrad, Deputy Solicitor, and Hope H. Augustini, Senior Litigation Counsel.