539 U.S. 1 (2003), 123 S. Ct. 2058, 156 L. Ed. 2d 1
Beneficial National Bank v. Anderson is a landmark Supreme Court decision on the scope of the complete preemption doctrine and its interaction with federal jurisdiction and removal.
Does the National Bank Act completely preempt state-law usury claims against national banks, such that a complaint pleading only state usury claims nonetheless arises under federal law and is removable to federal court?
Under the complete preemption doctrine, when Congress clearly intends a federal statute to provide the exclusive cause of action for a particular type of claim and supplies the substantive standard and remedies, any complaint raising that type of claim is necessarily federal in character for purposes of 28 U.S.C. § 1331 and is removable under 28 U.S.C. § 1441, notwithstanding the well-pleaded complaint rule. Sections 85 and 86 of the National Bank Act expressly govern the interest national banks may charge and create the exclusive federal cause of action and remedies for usury claims against national banks (including forfeiture and recovery of twice the interest paid within a two-year limitations period). Therefore, state-law usury claims against national banks are completely preempted.
Yes. The National Bank Act completely preempts state-law usury claims against national banks. A complaint alleging that a national bank charged usurious interest necessarily arises under federal law and is removable to federal court.
Beneficial National Bank v. Anderson broadens the complete preemption doctrine to include the National Bank Act's usury provisions, clarifying that some federal statutes both set the substantive standard and provide exclusive remedies, thereby converting state-law claims into federal ones for jurisdictional purposes. For law students, it is a key case at the intersection of Federal Courts (arising-under jurisdiction, removal, well-pleaded complaint, and artful pleading) and Banking Law (uniform federal regulation of national banks). It also underscores litigation strategy: defendants can remove usury suits against national banks, and plaintiffs must frame such claims under § 86 with its specific remedies and two-year limitations period.