Securities & Exchange Commission v. DeYoung, 850 F.3d 1172

APS, a nonbank administrator, commingled IRA owner funds in a Master Trust Account at First Utah; APS CEO Curtis DeYoung misappropriated about $24 million.
SEC sued APS and DeYoung; the district court appointed a Receiver to collect assets and pursue claims on behalf of APS/receivership.
Receiver negotiated a settlement with First Utah and its insurer (Everest) for over $5 million (First Utah $2M, Everest $3M), conditioned on a Claims Bar Order permanently enjoining other suits against First Utah relating to APS IRAs.
Approximately 99.98% of ~5,500 IRA owners approved the settlement; three intervenors objected only to the Claims Bar Order and sought to preserve their right to sue First Utah in state court.
The district court approved the settlement, entered the Claims Bar Order, made detailed factual findings (including First Utah’s limited capital and the “wasting” nature of the Everest policy), and certified the order as immediately appealable.
The Tenth Circuit affirmed: it rejected Anti-Injunction Act and standing/due-authority challenges and found the court’s factual findings were not clearly erroneous.

Issue	Plaintiff's Argument (Intervenors)	Defendant's Argument (Receiver/SEC/First Utah)	Held
Whether the Claims Bar Order violates the Anti‑Injunction Act	The Order impermissibly enjoins state‑court litigation and thus is barred by the Act	The Act bars stays of existing state proceedings only; no state action was pending when the bar issued	The Act does not apply; injunction valid in this respect
Whether the district court/Receiver had authority to bind IRA owners and bar separate claims (standing/abuse of discretion)	Receiver lacked standing to assert investors’ claims; court abused discretion by entering a broad bar	APS/Receiver had standing (APS suffered injury traceable to First Utah); court has broad equitable power in receiverships and settlement required the bar	No abuse of discretion; Receiver had standing and court properly approved the Claims Bar Order
Whether key factual findings supporting the bar (First Utah’s limited capital; settlement cap) are unsupported/clearly erroneous	Findings re: First Utah’s inability to pay more and regulatory risk were unsupported; without them bar is unjustified	Court conducted detailed financial inquiry, relied on public reports, consultants, and potential insurance depletion; contrary expert was given less weight	Findings supported by record and not clearly erroneous; trial court could discount intervenors’ expert

Ambort v. United States, 392 F.3d 1138 (10th Cir. 2004) (standard of review for Anti‑Injunction Act issues)
Friends of the Earth, Inc. v. Laidlaw Envtl. Servs., Inc., 528 U.S. 167 (2000) (Article III standing requirements)
Atlantic Coast Line R.R. Co. v. Brotherhood of Locomotive Eng’rs, 398 U.S. 281 (1970) (scope of Anti‑Injunction Act discussed)
Dombrowski v. Pfister, 380 U.S. 479 (1965) (Anti‑Injunction Act does not bar injunctions preventing institution of state suits)
Lippoldt v. Cole, 468 F.3d 1204 (10th Cir. 2006) (standing reviewed de novo)
Commodity Futures Trading Comm’n v. Chilcott Portfolio Mgmt., Inc., 713 F.2d 1477 (10th Cir. 1983) (district courts’ broad equitable discretion in receivership relief)
SEC v. Vescor Capital Corp., 599 F.3d 1189 (10th Cir. 2010) (recognizing wide discretion in equity receiverships)
Mathis v. Huff & Puff Trucking, Inc., 787 F.3d 1297 (10th Cir. 2015) (clear‑error standard for factual findings)
Wuliger v. Mfr’s Life Ins. Co., 567 F.3d 787 (6th Cir. 2009) (distinguishing receivership standing when the receivership entity itself lacks a cognizable injury)