This Note adds to the literature about federal agency actions on victims’ behalf by incorporating recent cases and comparing cases about courts’ power to parens patriae cases. Part I describes these two lines of cases: the parens patriae cases that define what states can do in federal court, and the cases on courts’ equitable powers in agency suits through Kokesh, Liu, and AMG Capital Management. Part II then considers potential practical issues with current agency processes, including a simple empirical analysis of the SEC’s records and how they might reflect the agency’s internal strategy and deadlines. Part III considers how a federal parens patriae framework distinct from states’ parens patriae standing could orient agency suits to victims’ benefit without contradicting existing law.



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