Overview
Case summary
The case involves Bartley, the Nebraska state treasurer, who sued Kent K. Hayden, the receiver of the insolvent Capital National Bank, to establish a claim for $285,357.85 deposited before the bank's failure. Hayden demurred, arguing the federal court lacked jurisdiction and the petition failed to state a cause of action. The Circuit Court held it had jurisdiction because the suit arose under U.S. laws governing national bank receiverships, irrespective of the parties' citizenship. The court overruled the demurrer, finding the petition sufficiently alleged a claim based on the receiver's federal duties.
Abstract
The state treasurer sued the receiver of an insolvent national bank to establish a claim for a pre-failure deposit. The receiver demurred, arguing lack of federal jurisdiction and failure to state a cause of action, but the court held jurisdiction existed under U.S. laws governing national bank receiverships and overruled the demurrer. The petition sufficiently alleged a claim based on the receiver's federal duties, allowing the case to proceed.
Opinion of the court
opinionfililí Ais. District Judge
- Jurisdiction exists under federal question jurisdiction
- Suit against national bank receiver arises under U.S. laws
- Petition's basis on federal duties is sufficient at demurrer stage
Jurisdiction
challenged- Defendant is receiver of a national bank appointed under U.S. laws
- Amount in dispute exceeds $2,000
Procedural posture
- Jurisdiction of federal court
- Whether petition states a cause of action
Legal categories
Case record
Issues & holdings
de novo
Case arises under U.S. laws because defendant's duties as receiver are defined by federal law
Issue preserved for review
de novo
Petition bases claim on defendant's federal duties as receiver, which is sufficient at demurrer stage
Issue preserved for review
Holdings of the court
Error analysis
- Defendant claimed court lacked jurisdiction and petition failed to state cause of action — procedural · no error foundNot applicable · not applicable
Statutory interpretation
1Standards of review
- Jurisdiction and sufficiency of petition — de novo Court reviews demurrer based on face of petition without deference
Timeline
Plaintiff, as Nebraska state treasurer, deposited $285,357.85 in Capital National Bank
Creates the debt that is the subject of the claim
Capital National Bank failed and suspended business
Triggers insolvency proceedings and appointment of receiver
Plaintiff presented verified claim to defendant as receiver
Formal demand for allowance of claim
Plaintiff again presented verified claim to defendant as receiver
Second demand for allowance of claim
Circuit Court overruled defendant's demurrer, holding it has jurisdiction and petition states a case
Outcome: Demurrer overruled
Court asserts jurisdiction and allows case to proceed
Facts & evidence
Incident
Key facts
6 facts- Plaintiff was Nebraska state treasurer in 1893
- Plaintiff deposited $285,357.85 in Capital National Bank on January 16, 1893
- Bank failed and suspended business on January 21, 1893
- Defendant appointed receiver by comptroller of currency
- Plaintiff presented verified claim to receiver on May 11 and June 15, 1893
- Receiver refused to allow claim
Procedural history
2 steps- Plaintiff filed amended petition to establish claim against receiver
- Defendant demurred on jurisdictional and failure-to-state-claim grounds
Evidence in the record
- Averments in petition regarding deposit and claim presentation
- Amended petition
- Verified claim presented to receiver
Objects of relevance
Authorities
Cited authorities (1)
Statutes
- Acts of Congress of 1887/1888 (jurisdictional statute)
- National Bank Acts (governing receiverships)
Standards & doctrines
- Federal question jurisdiction doctrine
- Principle from Bock v. Perkins on duties of federal officers
Legal principles applied
- Jurisdiction depends on whether claim is based on U.S. laws, not on its merits
- Equitable jurisdiction not invoked if adequate legal remedy exists