Mealey's (May 1, 2019, 1:41 PM EDT) -- ATLANTA — Although a federal district court did not err in appointing a receiver in a Ponzi scheme action and in using certain summary proceedings, those summary proceedings used by the district court failed to provide investors in the Ponzi scheme with a “meaningful opportunity” to challenge the determinations and calculations made by the receiver or to argue the claims and defenses they had, an 11th Circuit U.S. Court of Appeals ruled April 30 in reversing and remanding a pair of appeals (Securities and Exchange Commission v. James A. Torchia, et al., Nos. 17-13560 and 17-13561, 11th Cir., 2019 U.S. App. LEXIS 12947)....