The Central Bank of Denver, N.A. v. First Interstate Bank of Denver, N.A., and Jack K. Naber case in 1993 revolved around the issue of whether a party could be held liable for aiding and abetting securities fraud under Section 10(b) of the Securities Exchange Act even if they did not commit the fraudulent act themselves. The Supreme Court ruled that there was no provision within this section to hold parties accountable for merely assisting in fraudulent activities; instead, it only applied to those who directly engaged in manipulative or deceptive practices related to securities trading. This decision significantly narrowed down potential defendants in private lawsuits involving alleged violations of federal securities laws by excluding secondary actors such as lawyers, accountants, or banks unless their actions were independently deceitful or manipulative.

In the dissenting opinion for Central Bank of Denver, N. A. v. First Interstate Bank of Denver, N.A and Jack K. Naber (1993), Justice Stevens argued that the majority's interpretation was too narrow in its understanding of Section 10(b) of the Securities Exchange Act and Rule 10b-5 by excluding aiding and abetting liability from these provisions' scope. He contended that this decision would undermine investor protection against fraudulent practices within securities markets because it would limit legal recourse only to primary violators while exempting those who assist them knowingly or recklessly in their deceptive conduct. Furthermore, he criticized the majority's reliance on legislative history as a basis for interpreting statutory language when there is no clear evidence indicating Congress intended to exclude secondary actors from liability under these laws.