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Flowers v. Bancrdito Int'l Bank Corp

Citation: 350 F. Supp. 3d 26Docket: Civil No. 18-1288 (FAB)

Court: United States District Court; November 5, 2018; Federal District Court

Narrative Opinion Summary

In a case involving financial disputes between Cedric Flowers, liquidator of Choice Bank Ltd., and Bancrédito International Bank Corporation, legal proceedings were initiated regarding the withdrawal of funds from accounts held at Bancrédito. Choice Bank, an international bank from Belize, faced a liquidity crisis and sought to transfer funds from Bancrédito, which was denied, leading to a breach of contract claim under Puerto Rico law. Bancrédito countered with motions to dismiss for failure to join Flowers as an indispensable party and filed an interpleader complaint over conflicting claims to funds in a subsidiary's account. The court recognized Flowers' authority as liquidator, allowing him to substitute as the party-plaintiff and access funds totaling over $14 million. Bancrédito's opposition was limited to the entitlement of accrued interest. The case concluded with the court granting Flowers' motions to withdraw funds, dismissing the remaining claims as moot, and confirming diversity jurisdiction under 28 U.S.C. § 1332. The litigation highlighted issues of liquidator authority, breach of contract, and the resolution of disputes over account funds, ultimately resulting in the dismissal of the case with prejudice due to the mootness of the controversy.

Legal Issues Addressed

Breach of Contract under Puerto Rico Law

Application: Choice Bank filed for breach of contract after Bancrédito denied the transfer of funds, citing provisions allowing account closure at Bancrédito's discretion.

Reasoning: Choice Bank subsequently filed for breach of contract under Puerto Rico law, seeking a preliminary injunction to prevent Bancrédito from retaining the funds, citing an imminent risk of economic ruin.

Diversity Jurisdiction

Application: The court confirmed diversity jurisdiction under 28 U.S.C. § 1332, as the parties were completely diverse and the amount in controversy exceeded $75,000.

Reasoning: The Court confirms the existence of diversity jurisdiction, as the parties are completely diverse and the amount in controversy exceeds $75,000, referencing 28 U.S.C. § 1332.

Grant of Preliminary Injunction

Application: The court granted the liquidator's motion to withdraw funds from accounts due to the imminent risk of economic ruin faced by the plaintiff.

Reasoning: The Court has granted Flowers' motion to withdraw funds from both Choice Bank and Choice Financial accounts, amounting to $12,726,460.80 and $1,642,200.00, respectively, while deeming the remaining motions moot.

Indispensable Party

Application: Bancrédito moved to dismiss the action for failing to join Flowers as an indispensable party, affecting the progression of the case.

Reasoning: Bancrédito sought to dismiss the action for failing to include Flowers as an indispensable party, leading the court to delay a preliminary injunction hearing until these issues were resolved.

Liquidator's Authority

Application: The court recognized Flowers' authority as liquidator to control and request funds from both Choice Bank and its subsidiary, Choice Financial International.

Reasoning: Evidence indicated that Choice Bank controls Choice Financial, undermining any claim from Choice Financial regarding the funds.

Mootness Doctrine

Application: The court determined the case to be moot due to the resolution of the fund dispute and dismissed the remaining claims with prejudice.

Reasoning: Litigation focused on the withdrawal of funds from two Bancrédito accounts, resulting in the dismissal of the complaint, counterclaims, and interpleader due to the resolution of the fund dispute.