Smiley v. Citibank (South Dakota), National Association
United States Supreme Court
517 U.S. 735 (1996)
Relevant factsFree
Under the National Bank Act, the law of a national bank's home state governs the interest it may charge; South Dakota-based Citibank (defendant) charged California customer Smiley (plaintiff) late fees legal in South Dakota but not California, and after California courts dismissed Smiley's suit, the federal Comptroller of the Currency issued a rule clarifying that "interest" under the Act includes late fees.
IssueFree
Whether the presumption against preemption applies to a court's interpretation of substantive statutory provisions.