Case Citator › Federal Home Loan Bank of Boston v. Moody's Corporation

Federal Home Loan Bank of Boston v. Moody's Corporation

Is it still good law? What later courts have actually done to this case.

Overruled in part
Court
First Circuit
Citation
821 F.3d 102
Decided
Confirmed treatments
1
Flagged citations read
37 of 37
Citing cases (total)
37
Treatment dates
2017

Status

Overruled in part
A reviewed court has overruled part of this case’s holding. Lightfoot v. Cendant Mortgage Corp. displaced Federal Home Loan Bank of Boston v. Moody's Corporation's holding that an identical federal charter clause alone confers subject matter jurisdiction. The confirmed treatment is listed below.
More on how this was screened

All 37 flagged citations have been read; later courts continue to apply its separate rule allowing transfer under 28 U.S.C. § 1631 when personal jurisdiction is lacking.

Every treatment on this page is written from the citing opinion itself, with a verbatim quote, never copied from a commercial citator. A citation flagged by our screen but not shown here was read and found not to weaken this case.

37 later cases cite Federal Home Loan Bank of Boston v. Moody's Corporation; 37 of those citations sat close to treatment language and were flagged for reading, and all of them have been read. Citations that did not sit near treatment language were not flagged and were not read one by one, so a court that weakened this case without using any of that language would not appear here.

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Treatments

Overruled in part

  • The Supreme Court held that the identical “court of competent jurisdiction” charter language requires an independent source of federal subject matter jurisdiction, contrary to the First Circuit's jurisdiction holding in Federal Home Loan Bank.

    Lightfoot v. Cendant Mortgage Corp. · Supreme Court of the United States · filed

    Two Circuits have likewise concluded that the language in Fannie Mae's sue-and-be-sued clause grants jurisdiction to federal courts. See Federal Home Loan Bank of Boston v. Moody's Corp., 821 F.3d 102 (C.A.1 2016) (Federal Home Loan Bank of Boston's identical sue-and-be-sued clause); Pirelli Armstrong Tire Corp. Retiree Medical Benefits Trust ex rel. Fed. Nat. Mortgage Assn. v. Raines, 534 F.3d 779 (C.A.D.C.2008) (Fannie Mae's sue-and-be-sued clause). Four Circuits have disagreed, finding that similar language did not grant jurisdiction. ... On this understanding, Fannie Mae's sue-and-be-sued clause is most naturally read not to grant federal courts subject-matter jurisdiction over all cases involving Fannie Mae. In authorizing Fannie Mae to sue and be sued "in any court of competent jurisdiction, State or Federal," it permits suit in any state or federal court already endowed with subject-matter jurisdiction over the suit.
    Read the full opinion on CourtListener →

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