BENEFICIAL NATIONAL BANK v. ANDERSON

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Case Basics
Docket No. 
02-306
Petitioner 
Beneficial National Bank
Respondent 
Anderson
Opinion 
Advocates
(Argued the cause for the respondents)
(Department of Justice, argued the cause for the United States, as amicus curiae, supporting the petitioners)
(Argued the cause for the petitioners)
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Facts of the Case 

Several H&R; Block customers, who took out loans from Beneficial National Bank in anticipation of their tax refunds, sued the bank in state court. The customers alleged that the bank charged excessive interest in violation of Alabama law. The bank asked that the case be heard in federal, rather than state, court, because the issues were covered under the National Bank Act (NBA), a federal law. The district court ruled in favor of the bank; the 11th Circuit Court of Appeals reversed, holding that the NBA did not completely preempt state laws governing lending rates and that the case could therefore be heard in state court.

Question 

Does the NBA require that any suits involving charges of excessive interest be heard in federal rather than state court?

Conclusion 
Decision: 7 votes for Beneficial National Bank, 2 vote(s) against
Legal provision: 28 U.S.C. 1441

Yes. In a 7-2 opinion delivered by Justice John Paul Stevens, the Court held that the National Bank Act preempted the state-law claim and provided the exclusive cause of action for usury claims against national banks. Thus, the claim arose under federal law. The Court reasoned that the provisions of the Act create a federal remedy for overcharges that is exclusive, even when a state complainant relies entirely on state law. "Because [sections of the Act] provide the exclusive cause of action for such claims, there is, in short, no such thing as a state-law claim of usury against a national bank," wrote Justice Stevens. Justice Antonin Scalia, joined by Justice Clarence Thomas, dissented.

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BENEFICIAL NATIONAL BANK v. ANDERSON. The Oyez Project at IIT Chicago-Kent College of Law. 23 October 2014. <http://www.oyez.org/cases/2000-2009/2002/2002_02_306>.
BENEFICIAL NATIONAL BANK v. ANDERSON, The Oyez Project at IIT Chicago-Kent College of Law, http://www.oyez.org/cases/2000-2009/2002/2002_02_306 (last visited October 23, 2014).
"BENEFICIAL NATIONAL BANK v. ANDERSON," The Oyez Project at IIT Chicago-Kent College of Law, accessed October 23, 2014, http://www.oyez.org/cases/2000-2009/2002/2002_02_306.