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Beneficial National Bank v. Anderson

539 U.S. 1 (2003)

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Beneficial National Bank v. Anderson

United States Supreme Court

539 U.S. 1 (2003)

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Facts

Twenty-six taxpayers (plaintiffs) exchanged their expected tax refunds for short-term loans from Beneficial National Bank (Beneficial) (defendant). The plaintiffs sued Beneficial, a national bank chartered under the National Bank Act (the Act), 12 U.S.C. § 85, and two others (defendants) in Alabama state court, alleging that the interest rates violated state usury laws. Nothing in the complaint referenced federal law. Nevertheless, the defendants removed the case to federal court. The defendants claimed that the Act set interest rates and provided the exclusive remedies available for violations, and the case could be removed under 28 U.S.C. § 1441. The plaintiffs moved for remand, which was denied. The district court certified the question of whether removal was proper to the court of appeals. The court of appeals reversed, holding the claim did not arise under federal law under the well-pleaded complaint rule or fall into the complete preemption doctrine exception. The United States Supreme Court granted certiorari to resolve a circuit split.

Rule of Law

Issue

Holding and Reasoning (Stevens, J.)

Dissent (Scalia, J.)

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