County Bannock v. City Pocatello

John B. Tenney associated with a number of individuals and entities for the purpose of transacting business in the Global Stock Exchange (GSE). Tenneys association with Ernst Tietjen (Tietjen) in JTT Venture (JTT) ultimately resulted in a civil suit against him under the Idaho Securities Act (the Act), I.C. § 30-1401, et seq. During their association Tenney prepared documentary materials that Tietjen brought into Idaho for the purpose of soliciting investors in GSE. Testimony and documentary evidence presented at trial indicated that Tenney knew about Tietjens activities in Idaho. The district court, acting as the trier of fact, found sufficient evidence to prove Tenneys liability under an aiding and abetting theory. Tenney timely filed an appeal challenging the judgment on three theories: (1) the court lacked jurisdiction over him as a citizen of Utah; (2) the court did not use the correct standard for fraud and aider-abettor liability; and (3) there was insufficient evidence to prove his liability for violations of the Act. For the reasons stated below we affirm the judgment.