Beneficial National Bank v. Anderson

Facts

Plaintiffs, twenty-six taxpayers, exchanged information regarding their expected tax refunds from short-term loans from Defendant, Beneficial National Bank. Thereafter, Plaintiffs initiated this action against Defendant, a national bank that is chartered under the National Bank Act, and two defendants in Alabama state court. Plaintiffs contend that their interest rates violated state usury laws. Plaintiffs complaint did not reference federal law. Nonetheless, all defendants removed the case to federal court on the grounds that the National Bank Act indicates the interest rates, which provided the applicable remedies available for the violations. Also, defendants assert the case is removable, pursuant to 28 U.S.C. § 1441. Plaintiffs motioned for a remand, but the court denied Plaintiff’s motion. Subsequently, the court certified the question of whether removal, in this case, is proper to the appellate court. The appellate court reversed the district court and held that the claim did not arise under federal law, pursuant to the well-pleaded complaint rule nor did the claim fall into the complete preemption doctrine exception. Thereafter, the United States Supreme Court granted certiorari to resolve the circuit split.