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Resolution Trust Corporation, as Receiver for Pelican Homestead and Savings Association v. United States Fidelity and Guaranty Company

Citations: 27 F.3d 122; 1994 U.S. App. LEXIS 17735; 1994 WL 371411Docket: 94-30199

Court: Court of Appeals for the Fifth Circuit; June 27, 1994; Federal Appellate Court

Narrative Opinion Summary

The case involves the Resolution Trust Corporation (RTC), which, as receiver for a failed savings association, sought to dismiss its appeal in a dispute over partial summary judgment with the United States Fidelity and Guaranty Company (USF&G). Initially, Pelican Homestead and Savings Association filed a lawsuit against USF&G for losses due to alleged fraudulent activities covered under a bond. After a state court granted partial summary judgment in favor of USF&G, the RTC, having been appointed as receiver, attempted to remove the case to federal court. The federal district court upheld the state court's judgment, treating it as final and appealable, and denied the RTC's motions for a new trial. The central legal issue revolved around whether the partial summary judgment was appealable, with federal and Louisiana laws providing differing interpretations. Despite the RTC’s argument for federal appealability rules, the court concluded the partial judgment was interlocutory and not subject to immediate appeal. Consequently, the court dismissed the RTC's appeal due to lack of jurisdiction, aligning with principles from the Meyerland case and emphasizing the need for federal courts to adhere to state court decisions in removal cases.

Legal Issues Addressed

Appealability of Partial Summary Judgments

Application: The case addresses the distinction between final and interlocutory judgments in determining the appealability of partial summary judgments under Louisiana law.

Reasoning: The analysis concluded that the partial summary judgment in the current case was also interlocutory and unappealable, leading to a lack of jurisdiction for the appeal.

Jurisdiction Over State Court Judgments in Federal Court

Application: Federal courts must accept state court judgments as they stand when cases are removed from state to federal jurisdiction, as mandated by 12 U.S.C. Sec. 1819(b)(2)(B) and FIRREA.

Reasoning: The procedural guideline stated that the district court must accept the state judgment as it is and prepare the case for federal appellate review.

Review Standards for State Law Interpretations

Application: Federal courts apply de novo review when assessing district court interpretations of state law concerning appealability.

Reasoning: The standard of review for such interpretations of state law is de novo.

RTC's Removal Powers Under FIRREA

Application: The RTC has the authority to remove cases from state to federal court without bond or security, similar to the FDIC's powers, under 12 U.S.C. Sec. 1441a(l)(3).

Reasoning: The RTC similarly has broad removal powers under 12 U.S.C. Sec. 1441a(l)(3), allowing it to transfer cases from state to federal court without bond or security, mirroring the FDIC's authority.