McDaniel v. Wells Fargo Investments, LLC, 2013 WL 1405949 (9th Cir. 2013)

In these four related class actions, plaintiffs (all former employees of large financial institutions) alleged that their firms' policies of forbidding employees from opening outside securities trading accounts violates Labor Code § 450(a), which prohibits an employer from compelling or coercing an employee to patronize his or her employer in the purchase of anything of value. The employers argued the state statute is preempted by the federal Securities Exchange Act and related regulatory rules. The district court agreed and dismissed the cases; the Ninth Circuit Court of Appeals affirmed the dismissals.