Beneficial National Bank v. Anderson

Twenty-six taxpayers (plaintiffs) sued Beneficial National Bank (defendant) in Alabama state court, claiming the interest rates on their tax-refund loans violated state usury law; the complaint mentioned only state law. Beneficial removed the case to federal court, arguing the National Bank Act set the interest-rate rules and remedies for national banks and preempted the state usury claim entirely. The district court denied the plaintiffs' motion to remand, and certified the removal question to the court of appeals, which reversed, holding the claim did not arise under federal law. The Supreme Court granted certiorari to resolve a circuit split.