Answer · confidence: partial
Since the Supreme Court limited wire fraud, do judges still allow coin-holder cases?
Research question: After Ciminelli and related Supreme Court decisions narrowed the wire fraud property theory, how have lower courts treated crypto manipulation cases where the alleged victim was a token holder rather than a traditional investor?
The records show a Northern District of California decision dated September 2, 2026, which largely denied motions to dismiss in the Jump class action and let core securities fraud and market manipulation claims proceed 2. The court allowed manipulation claims based on allegations that Jump bought UST above market prices to artificially support its value, and it reaffirmed that UST could be treated as a security 45. Plaintiffs alleged a secret arrangement with Terraform founder Do Kwon to restore UST's peg after it lost its dollar value in May 2021 6. The facts do not say whether these plaintiffs were token holders rather than traditional investors, nor do they describe how Ciminelli itself was applied in these cases, so the question is only partly answered 13. The newest dated fact is September 2, 2026, about a month before October 2026, and the South Korean acquittal is not a US wire fraud ruling and does not address Ciminelli 8.
Checked 2026-10-22. Only documented and supported facts are used.
Dig deeper on this questionSources
[1] supported
Wire fraud charges in crypto wash-trading cases do not depend on whether the token is classified as a security.
"It does not require that the token be classified as a security."Federal Prosecutors Are Charging Crypto Market Makers with Wire Fraud and Market Manipulation — Armstrong & Bradylyons PLLC
[2] supported
The Northern District of California largely denied motions to dismiss in the Jump securities class action, letting core securities fraud and market manipulation claims proceed.
"In a September 2, 2026, opinion , the Northern District of California largely denied motions to dismiss, allowing core securities fraud and market manipulation claims to proceed."Crypto Securities Suit Survives Motion to Dismiss
[3] supported
The Supreme Court in Kousisis unanimously held that wire fraud can be established for inducing a transaction under materially false pretenses, even without proof of net economic loss.
"The Court unanimously held that a defendant can be convicted of wire fraud for inducing a victim to enter a transaction under materially false pretenses, even without proof of net economic loss."Federal Prosecutors Are Charging Crypto Market Makers with Wire Fraud and Market Manipulation — Armstrong & Bradylyons PLLC
[4] supported
The court held that market manipulation claims could proceed based on allegations that Jump bought UST above market prices to artificially support its value.
"as well as market manipulation claims premised on allegations that Jump purchased UST at above-market prices to artificially support the stablecoin’s value."Crypto Securities Suit Survives Motion to Dismiss
[5] supported
The court reaffirmed that UST could be treated as a security, even though regulatory developments addressed reserve-backed stablecoins.
"Significantly, the court reaffirmed its earlier conclusion that UST could be treated as a security, notwithstanding regulatory developments addressing reserve-backed stablecoins, which the court found did not affect its analysis of UST’s status."Crypto Securities Suit Survives Motion to Dismiss
[6] supported
Plaintiffs alleged that Jump entered a secret arrangement with Terraform founder Do Kwon to buy large quantities of UST and restore its peg after it lost the dollar value in May 2021.
"Jump entered into a secret arrangement with Kwon to purchase large quantities of UST to restore the peg."Crypto Securities Suit Survives Motion to Dismiss
[7] supported
The court allowed disclosure and market manipulation claims to proceed against a participant in the Terraform platform that was not the issuer of the underlying asset.
"the court permitted key disclosure and market manipulation claims to proceed against a participant in the Terraform platform that was not itself the issuer of the underlying asset."Crypto Securities Suit Survives Motion to Dismiss
[8] supported
A South Korean court acquitted crypto operator Jonber Kim after prosecutors failed to prove that individual investors bought the tokens because they were misled by project promotions. This is a South Korean ruling, not a US wire fraud decision, so it does not directly address Ciminelli.
"Prosecutors did not prove that individual investors bought the tokens because they were misled by those claims."South Korean Court Acquits Jonber Kim in $230 Million Crypto Case.
[9] supported
The Second Circuit affirmed dismissal of the plaintiffs' federal securities law claims against Uniswap, reasoning that a smart contract drafter should not be liable under the Exchange Act for a third-party user's misuse of the platform.
"it defies logic that a drafter of a smart contract, a computer code, could be held liable under the Exchange Act for a third-party user's misuse of the platform."Second Circuit Strikes Down Attempt to Pin Fraud on Token Issuers
[10] supported
Prosecutors also lacked enough evidence to support charges that Kim manipulated token prices or diverted proceeds from POD sales.
"Prosecutors also failed to provide enough evidence to support charges that Kim manipulated token prices or diverted proceeds from POD sales."South Korean Court Acquits Jonber Kim in $230 Million Crypto Case.
[11] supported
After affirming dismissal of the federal claims, the Second Circuit sent the remaining state-law claims back to the district court for consideration.
"However, the Second Circuit directed the lower court to consider Plaintiffs’ state-law claims."Second Circuit Strikes Down Attempt to Pin Fraud on Token Issuers
[12] supported
The district court held that operating a marketplace where many users interact legitimately is not substantial assistance to fraud, even if some users act fraudulently, and that plaintiffs had to show affirmative assistance, concealment, or a failure to act when required.
"The court further held that creating a marketplace on which many users could interact legitimately did not constitute “substantial assistance” in facilitating the scams, even if some users acted fraudulently."Second Circuit Strikes Down Attempt to Pin Fraud on Token Issuers