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Marquette National Bank of Minneapolis v. First of Omaha Service Corporation

United States Supreme Court
439 U.S. 299 (1978)

Written by Heather Whittemore, JD

Facts

The First National Bank of Omaha (Omaha Bank) (defendant) was a national bank located in Nebraska. Omaha Bank issued credit cards through its BankAmericard program, allowing cardholders across the country to obtain credit cards through Omaha Bank. Omaha Bank specifically solicited customers from Minnesota. Omaha Bank charged its cardholders an 18 percent annual interest rate on their first $999.99 and a 12 percent annual interest rate on amounts $1,000 and over. These interest rates were set pursuant to Nebraska’s usury laws. Minnesota’s usury laws limited interest rates to 12 percent. Marquette National Bank of Minneapolis (Marquette) (plaintiff), a Minnesota bank that also participated in the BankAmericard program, filed a lawsuit in Minnesota state court against Omaha Bank, arguing that Omaha Bank violated Minnesota law by charging customers in Minnesota higher interest rates than allowed in Minnesota. The district court granted partial summary judgment for Marquette, holding that Minnesota state law should be applied to Omaha Bank. The Minnesota Supreme Court reversed the district court, holding that according to the National Bank Act, Nebraska law should govern Omaha Bank’s BankAmericard program in Minnesota. Marquette appealed. The United States Supreme Court granted certiorari.

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Holding and Reasoning (Brennan, J.)

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