On 4 June 2014, the Second Circuit Court of Appeals ruled that Judge Jed S. Rakoff exceeded his authority by demanding that Citigroup do more than pay a fine without admitting wrongdoing. Judge Rakoff had refused to approve a settlement between the SEC and Citigroup in 2011 on the basis that it was too lenient. The appeals court said the Judge “abused [his] discretion by applying an incorrect legal standard” of review.