On November 19, 2018, the U.S. Court of Appeals for the D.C. Circuit overturned the SEC’s draconian enforcement sanctions against an investment advisory firm and remanded the case to the SEC to initiate an entirely new enforcement action. The decision was a victory for WLF, which filed a brief arguing that the SEC Administrative Law Judge (ALJ) who imposed the sanctions was appointed unconstitutionally and lacked authority to decide the case. In June 2018, the U.S. Supreme Court’s ruling in a separate case, Lucia v. SEC, endorsed WLF’s argument. In response to that ruling, the appeals court vacated the ALJ’s sanctions against Timbervest and ordered a rehearing before a new SEC official. In light of its ruling, the appeals court had no need to address WLF’s separate argument that the charges against Timbervest (which related to activities that occurred in 2007 and did not result in losses by any investors) are barred by the five-year statute of limitations.