On April 9th, the Ninth Circuit affirmed the dismissal of four putative class action lawsuits filed against various broker-dealers. California state law prohibits employers from forcing their employees to patronize them. Plaintiffs, employees of the broker-dealers, claimed that the broker-dealers violated that law by requiring employees wishing to open self-directed brokerage accounts to do so in-house. The Ninth Circuit held that the federal securities laws preempt the state law. The in-house brokerage requirement is based on Congress' directive requiring brokerage houses to prevent their employees from engaging in "harmful or unfair trading practices." McDaniel.