Market Manipulation. Search

SEC v. William T. Walters, et al. (insider trading, 2018)

Settled

Checked against the primary document on October 2, 2026. The library's summary, tags and figures for this record were compared with the regulator's own document by an AI model (Claude) following written instructions, with sampled and disputed records read a second time. No lawyer has reviewed them. A checked record can still contain errors, and checked does not mean endorsed. See how we check records or report a correction.

Report an error in this record (sec-william-t-walters-et-al-insider-trading-2018) by email

In April 2018 a federal court approved settlements between the SEC and William Walters and Dean Foods director Thomas Davis in an insider trading case. Walters agreed to disgorge $19,004,429.26 plus interest, and Davis agreed to settle charges that he tipped Walters.

The record

Structured fields for this action, as recorded in our case library.
Agency SEC
Release number LR-24125
Date filed 2018-04-30
Court U.S. District Court, Southern District of New York
Status settled
Criminal parallel Yes: convicted (William Walters (convicted); Thomas C. Davis pleaded guilty)
Defendants William T. Walters, et al. (individual)
Cited as charged or alleged Exchange Act s.10(b) and Rule 10b-5 (statutes and rules cited in the document; not a finding that they were violated)
Techniques Insider trading

What was ordered

Civil penalty
—
Disgorgement
$19m
Prejudgment interest
—
Total relief
$19m
Alleged gain
—

A dash means the release did not state a figure we could extract, not that the figure is zero. Penalty and disgorgement are stored separately so aggregates across the library do not double-count the same dollars.

What is alleged to have happened

The Securities and Exchange Commission announced the settlements on April 30, 2018 as litigation release 24125, in a case filed in May 2016.

The complaint alleges Davis, a Dean Foods board member who owed Walters money, regularly passed him inside information, using prepaid phones, in return for nearly $1 million in benefits, and that Walters made millions trading on it.

The record previously said the matter was dismissed; the court approved the settlements on April 17, 2018.

For the regulator's own account of the facts, read the primary document linked above. This page deliberately summarises the structured record rather than reproducing the release.

What technique is this, and how does it work?

This action is tagged with one technique in our taxonomy. The tagging is ours: regulators charge statutory provisions, not technique names, so the mapping is an editorial judgement described in our editorial policy.

Timeline

  1. 2018-04-30 Litigation release published

Primary documents

Everything on this page derives from the documents below. Where our summary and the primary document disagree, the primary document is right.

The linked release is a work of the United States government and is not subject to copyright. Our summary and narrative above are our own writing.

Other actions in the library sharing at least one technique tag with this one.

Action Agency Filed Technique Penalty Status
SEC v. Trijya Vakil and Neeraj Visen (insider trading, 2026) SEC 2026-09-04 Insider Trading $109k settled
CFTC v. Gabriel Perez (insider trading, 2026) CFTC 2026-08-28 Insider Trading $65k judgment
SEC v. Gavin Wolfe and others (insider trading, 2026) SEC 2026-08-21 Insider Trading — filed
SEC v. Jesse R. Mitchell (insider trading, 2026) SEC 2026-08-21 Insider Trading — filed
SEBI v. Arun Kumar Somani and others (insider trading review, Indian Oil Corporation, 2026) SEBI (India) 2026-08-13 Insider Trading — dismissed
SEC v. Benjamin Tesfaye (insider trading, 2026) SEC 2026-08-11 Insider Trading $18.7k settled

Record added September 10, 2026. submit a correction.