James C. Sell

Summary

The court held that the Arizona Securities Act does not authorize a separate cause of action for aiding and abetting another person's securities fraud. Because the Act does not expressly impose secondary liability, and the court found no material difference between the relevant state and federal provisions, it followed the federal statutory-text approach and overruled its prior contrary holding. The court affirmed summary judgment for the defendants on the aiding-and-abetting count.