Key Takeaways:
- A federal judge dismissed all securities claims against Caitlyn Jenner’s JENNER meme coin with prejudice on April 16, 2026.
- Judge Blumenfeld ruled that JENNER failed the common enterprise prong of the Howey Test, setting a precedent for meme coin litigation.
- California state-law fraud claims dismissed without prejudice, leaving plaintiffs the option to refile in state court.
Central District of California Dismisses JENNER Securities Claims, Leaves State Fraud Case Open
U.S. District Judge Stanley Blumenfeld Jr. of the Central District of California issued the order on April 16, 2026, granting defendants’ motion to dismiss the Second Amended Complaint in Naeem Azad et al. v. Caitlyn Jenner et al. (Case No. 2:24-cv-09768). A separate final judgment was entered the same day, terminating the federal case.
The decision centers on the Howey Test, the Supreme Court framework used to determine whether a financial product constitutes an “investment contract” under securities law. To qualify, a transaction must involve an investment of money in a common enterprise with an expectation of profits derived from the efforts of others.
Judge Blumenfeld found that lead plaintiff Lee Greenfield failed to satisfy the common enterprise prong. The court found the complaint did not plausibly allege that investors pooled resources or agreed to share profits and losses beyond the purchase of the coin itself, including through the token’s alleged transaction tax, buybacks, or marketing activity.
Because the common enterprise element was not met, the court did not reach the third prong regarding expectations of profit from others’ efforts. Federal securities claims were dismissed with prejudice on the merits as to Greenfield.
California state-law claims, including common-law fraud and quasi-contract, were dismissed without prejudice. The court declined to exercise supplemental jurisdiction over those claims, leaving plaintiffs the option to refile in state court. Claims from all putative class members other than Greenfield were also dismissed without prejudice.
Jenner launched the JENNER meme coin on Solana on May 26, 2024, and on Ethereum shortly after. The token was promoted heavily through social media, including posts on X that featured AI-generated imagery with messages suggesting profit potential, according to the class action. The Rosen Law Firm filed the original class action in November 2024 on behalf of purchasers of the token during the class period.
Plaintiffs argued Jenner’s celebrity status and promotional activity created a reasonable expectation of profits from her efforts, which would satisfy the Howey standard. Jenner and her then-business manager, Sophia Hutchins, were named as defendants. Hutchins died in July 2025. Jenner’s legal team maintained throughout that the token was not a security.
The court first dismissed the initial complaint on May 9, 2025, finding that plaintiffs, many of them foreign investors, failed to adequately allege U.S.-based transactions. Plaintiffs amended their complaint and added Greenfield, a UK citizen described as having suffered losses exceeding $40,000, as lead plaintiff.
Jenner previously described the lawsuit as meritless and established a legal defense fund, citing potential consequences for the broader digital asset industry if the case had gone the other way.
The ruling adds to a growing body of case law distinguishing speculative meme tokens from regulated securities. It does not bind the Securities and Exchange Commission (SEC) or other courts, and each meme coin case turns on its specific facts and allegations.
The decision may still influence litigation involving other celebrity-endorsed tokens, including those tied to public figures and political personalities. Courts and legal teams can now reference the Blumenfeld ruling when applying the Howey framework to similar assets.
No immediate appeal has been reported. The final judgment closes the federal proceeding, and the underlying state-law questions remain unresolved pending any refiling in California state court.
