A federal judge in California has dismissed all federal securities claims tied to Caitlyn Jenner’s JENNER meme coin, ruling that the token does not qualify as a security under federal law. The order was issued on April 16, 2026, and a separate final judgment entered the same day closed the federal case.
The case, Naeem Azad et al. v. Caitlyn Jenner et al., case number 2:24-cv-09768, was heard in the U.S. District Court for the Central District of California. Judge Stanley Blumenfeld Jr. granted the defendants’ motion to dismiss the Second Amended Complaint. Law360 and Bloomberg Law were first to report the decision.
Common enterprise requirement was the key issue
The ruling turned on the Howey Test, the Supreme Court framework used to determine whether a transaction amounts to an investment contract. Under that standard, a product must involve an investment of money in a common enterprise with an expectation of profits derived from the efforts of others.
Judge Blumenfeld found that lead plaintiff Lee Greenfield failed to satisfy the common enterprise element. According to the court, the complaint did not plausibly show that investors pooled resources or agreed to share profits and losses beyond buying the token itself. Allegations involving the token’s transaction tax, buybacks, and promotional activity were not enough to establish that element. Because the common enterprise prong failed, the court did not analyze the third part of Howey dealing with profit expectations based on others’ efforts.
That finding led the court to dismiss the federal securities claims with prejudice on the merits as to Greenfield. In practical terms, those federal securities claims cannot be refiled in the same form in federal court.
State-law claims were left open for possible refiling
The plaintiffs had also brought California state-law claims, including common-law fraud and quasi-contract. Those claims were dismissed without prejudice, not on their substance, but because the federal court declined to keep exercising supplemental jurisdiction after disposing of the federal claims.
That leaves the plaintiffs free to pursue those issues in California state court if they choose. Claims brought by all proposed class members other than Greenfield were also dismissed without prejudice.
Token launch and promotion were central to the complaint
According to the class action, Jenner launched the JENNER token on Solana on May 26, 2024, and later on Ethereum. The complaint said the token was heavily promoted on social media, including posts on X featuring AI-generated imagery and messages that suggested profit potential.
The original class action was filed by Rosen Law Firm in November 2024 on behalf of purchasers who bought the token during the class period. Plaintiffs argued that Jenner’s celebrity status and promotional conduct created a reasonable expectation that buyers would profit from her efforts, which they said should satisfy Howey. Jenner and her then-business manager, Sophia Hutchins, were named as defendants. The report states that Hutchins died in July 2025.
An earlier dismissal focused on U.S. transaction allegations
This was not the court’s first dismissal in the case. On May 9, 2025, the court dismissed the initial complaint, finding that the plaintiffs, many of them foreign investors, had not adequately alleged U.S.-based transactions. The plaintiffs then amended their filing and added Greenfield, a UK citizen described as having losses exceeding $40,000, as lead plaintiff.
Jenner had previously called the lawsuit meritless and created a legal defense fund, saying an adverse result could affect the broader digital asset industry.
Ruling may be cited in future meme coin litigation
The decision adds to the growing set of court opinions separating speculative meme tokens from assets that fall under securities regulation. It does not bind the U.S. Securities and Exchange Commission or other courts, and the outcome of any meme coin case still depends on its own facts and allegations.
Even so, lawyers handling disputes over celebrity-backed tokens or projects tied to public figures may now point to the Blumenfeld ruling when arguing over the Howey framework. No immediate appeal had been reported.