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Oklahoma Central Credit Union v. United States of America, Ex Rel. National Credit Union Administration

Citations: 16 F.3d 416; 1993 U.S. App. LEXIS 37725Docket: 92-5239

Court: Court of Appeals for the Tenth Circuit; December 13, 1993; Federal Appellate Court

Narrative Opinion Summary

In the case of Oklahoma Central Credit Union v. United States, the Tenth Circuit Court of Appeals reviewed a district court order related to claims brought by a state-chartered credit union. The plaintiff alleged that the defendant's actions violated the Fifth Amendment by permitting overlapping membership fields with the Communication Federal Credit Union, constituting a taking of property without due process, and breached its fiduciary duty. The district court dismissed these claims, citing lack of jurisdiction and recognizing that exclusive jurisdiction lay with the Court of Federal Claims under the Tucker Act. The court retained jurisdiction over a third claim concerning the alleged arbitrary and capricious actions of the defendant, which was ultimately found to be unsubstantiated. The Tenth Circuit affirmed the district court's decisions, agreeing that the statutory 'sue and be sued' clause did not override the Tucker Act's jurisdiction. The appellate court's order, which holds no precedential value, clarifies jurisdictional boundaries and standards for judicial review in cases involving federal agency actions.

Legal Issues Addressed

Arbitrary and Capricious Standard of Review

Application: The agency's decision to allow overlapping fields of membership was not arbitrary or capricious, nor did it violate agency policies.

Reasoning: Upon reviewing the agency's decision, it was determined that the defendant did not act arbitrarily or capriciously in allowing overlapping fields of membership, nor did this decision violate agency policies.

Citation of Unpublished Opinions

Application: The court permits citation of unpublished opinions if they have persuasive value on a material issue and are properly provided to the court and parties.

Reasoning: Citation of unpublished opinions is permitted if they have persuasive value on a material issue and are properly attached or provided to the court and parties, as per the General Order of November 29, 1993.

Interpretation of 'Sue and Be Sued' Clause

Application: The statutory 'sue and be sued' clause does not clearly indicate a withdrawal of exclusive jurisdiction from the Court of Federal Claims regarding the plaintiff's damages claims.

Reasoning: The Tenth Circuit agreed that the statutory 'sue and be sued' clause did not clearly indicate a withdrawal of exclusive jurisdiction from the Court of Federal Claims regarding the plaintiff's damages claims.

Jurisdiction under the Tucker Act

Application: The district court found exclusive jurisdiction for the taking and breach of fiduciary duty claims rested with the Court of Federal Claims under the Tucker Act.

Reasoning: The district court found it lacked jurisdiction over the taking and breach of fiduciary duty claims, determining that exclusive jurisdiction rested with the Court of Federal Claims under the Tucker Act.

Prematurity of Claims under the Tucker Act

Application: Claims are considered premature if the property owner has not utilized the processes outlined in the Tucker Act.

Reasoning: Claims are considered premature if the property owner has not utilized the processes outlined in the Tucker Act.