S.E.C. v. Graham: S.D. Fla. Holds that 28 U.S.C. § 2462’s Five-Year Statute of Limitations is Jurisdictional, Applies to All Forms of Relief
On May 12, 2014, Judge James Lawrence King of the United States District Court for the Southern District of Florida held in S.E.C. v. Graham that the general five-year statute of limitations governing civil penalty actions brought by the government, 28 U.S.C. § 2462, jurisdictionally barred the Court from considering a complaint brought by the Securities and Exchange Commission (“SEC”) more than five years after the last sale or offering of securities alleged to have violated the securities laws occurred.