Court Dismisses Federal Securities Claims
On April 17, 2026, U.S. District Judge Stanley Blumenfeld, Jr. ruled that Caitlyn Jenner’s $JENNER memecoin is not a security, dismissing the core federal claims in a class action lawsuit filed by plaintiff Lee Greenfield, per The Block. Greenfield claimed he lost over $40,000 investing in $JENNER tokens launched on Ethereum and Solana in May 2024, alleging that Jenner and her manager (the late Sophia Hutchins) promoted the token as an investment with promises of profit, per.
Howey Test Analysis Leads to Dismissal
Judge Blumenfeld applied the Howey Test — the 1946 Supreme Court standard defining an “investment contract” as a security. He determined that the complaint failed to plausibly allege a common enterprise, a required element of the test, per. The order stated that investors did not pool resources or agree to share profits and losses beyond simply buying the token itself, including through any alleged transaction tax, buybacks, or marketing efforts, per.
“Because Greenfield does not plausibly allege either horizontal or vertical commonality, he has not alleged the existence of a common enterprise,” the judge wrote. As a result, the court did not need to evaluate the third prong — whether investors expected profits solely from Jenner’s promotional efforts, per.
Remaining Claims and Broader Context
The judge dismissed the federal securities claims but noted that other non-federal claims could still be pursued in state court, per. The lawsuit stemmed from Jenner’s social media posts, including an AI-generated image suggesting the token could “make everyone rich,” which plaintiffs argued created an expectation of profit, per.
This ruling adds to a growing body of cases examining whether celebrity-backed memecoins qualify as securities under the Howey Test. It highlights the challenges plaintiffs face when trying to prove a common enterprise in decentralized token launches, especially when promotional efforts are framed as community-driven rather than centralized investment schemes.
Market and Regulatory Implications
The decision may influence how courts view similar celebrity memecoin projects. While $JENNER was not deemed a security in this federal case, regulatory scrutiny of memecoins and influencer promotions continues, particularly from the SEC. Investors should remain cautious, as outcomes can vary by jurisdiction and specific facts of each case.
