In theUnited States v.O'Hagan case referenced in the text,O'Hagan was a partner in the law firm of Dorsey & Whitney who represented Grand Met.Grand Met revealed to O'Hagan that Grand Met intended to make a tender offer to Pillsbury.Based on this confidential material information form his client O'Hagan purchased stock and options in Pillsbury prior to a public announcement of Grand Met's tender offer for Pillsbury.O'Hagan realized over $4million in profits but was later convicted of insider trading.The U.S.Supreme Court upheld O'Hagans criminal conviction based on the:

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The Missappropriation Theory of Insider Trading was applied in the United States v. O'Hagan case. This theory holds that it is illegal to trade on material nonpublic information obtained through a breach of a duty of trust and confidence owed to the source of the information, even if the trader is not an insider of the company whose securities are being traded. O'Hagan breached his duty of trust and confidence by using information obtained from his client (Grand Met) to trade in Pillsbury securities for his own benefit. The Supreme Court found him guilty of insider trading under the Missappropriation Theory.

In TheUnited States V