Supreme Court of the United States
Whitney National Bank in Jefferson Parish v. Bank of New Orleans & Trust Co.
January 18, 1965379 U.S. 411
Summary
The Court held that the district court lacked jurisdiction to decide challenges to a bank holding company's organization and operation of a new national bank because the Bank Holding Company Act committed those issues initially and exclusively to the Federal Reserve Board, subject to review in the courts of appeals. The Comptroller's certificate was not final agency action and could not be used as the basis for a collateral attack on the Board's approval. The judgments were reversed, the complaint was directed to be dismissed, and issuance of the judgment was stayed for 60 days to permit proceedings seeking a remand to the court of appeals and further consideration by the Board. Justices Douglas and Black, dissenting, would have recognized district-court jurisdiction and either decided the Louisiana-law issue themselves or affirmed the lower-court judgment.
Holding
- Initial jurisdiction over challenges to the holding-company plan. The district court lacked jurisdiction to decide whether Whitney-Jefferson's organization and operation under the holding-company plan complied with federal or state law. Those issues had to be presented first to the Federal Reserve Board, which had original exclusive jurisdiction over the propriety of the plan.
- Exclusivity of the statutory administrative-review procedure. Challenges to the Board's approval of the organization and operation of a new bank by a bank holding company had to proceed through the statutory administrative process and review in the courts of appeals, rather than through a collateral action in a district court against the Comptroller.
- Finality of the Comptroller's certificate and treatment of the new Louisiana statute. The Comptroller's contemplated certificate was not final agency action for purposes of judicial review because it could have no operative effect if the Board's approval of the holding-company plan were later reversed. The new Louisiana statute had to be considered initially by the Federal Reserve Board in the pending review proceedings.
Docket 26