Chau v. United States Securities & Exchange Commission
This case involves Wing F. Chau and Harding Advisory LLC (plaintiffs) seeking to enjoin an administrative proceeding initiated by the Securities and Exchange Commission (SEC). Plaintiffs argue that the SEC's choice of an administrative forum, instead of a federal district court, violates their due process and equal protection rights. The court, applying the Thunder Basin and Free Enterprise Fund factors, concludes it lacks subject matter jurisdiction to interrupt the ongoing agency adjudication. The court found that SEC adjudication would not foreclose meaningful judicial review, the claims were not wholly collateral to the SEC proceeding, and the SEC was competent to consider the fairness of its proceedings and related constitutional claims in the first instance. Therefore, the court denied the plaintiffs' motion for a preliminary injunction and granted the SEC's motion to dismiss the action.