Rose was the president of a small oil and gas company. He was convicted for securities fraud relating to the sale of limited partnership interests in an oil well venture without disclosing to investors that the equipment and land were encumbered. Rose appealed, claiming that because the encumbrances were matters of public record, the investors had constructive notice.

The case and case summary are also available online at: http://www.mlmlegal.com/legal-cases/Rose_v_Texas.php