No. 18-1269October Term 2019Decided Feb 25, 2020
Rodriguez v. FDIC
This case resolved the legal rule for deciding who owns a corporate group's tax refund when the parent receives the check but a subsidiary's losses produced it.
Case status
- Current stage
- Decided
- Latest event
- Decision released Feb 25, 2020
- What it's about
This case is about who owns a federal tax refund paid to a corporate group when the refund is sent to the parent company but was generated by a subsidiary’s losses. The Court considered whether that ownership dispute should be decided under a judge-made federal rule or under ordinary state law.
Question presented
Whether courts should determine ownership of a tax refund paid to an affiliated group based on the federal common law "Bob Richards rule," as three Circuits hold, or based on the law of the relevant State, as four Circuits hold.
- Case path
United States Court of Appeals for the Tenth Circuit / Decision released Feb 25, 2020
- Area
Business and Regulation
Briefing
What it's about
Rodriguez v. FDIC asked who owns a federal tax refund paid to a corporate group when the refund was sent to the parent company but was generated by a subsidiary's losses. On Feb. 25, 2020, the Supreme Court decided that courts must resolve that kind of ownership fight by choosing between the Bob Richards rule and state law, though the prompt does not provide the opinion's exact vote or language.
Vote
The case was argued on Dec. 3, 2019, and decided on Feb. 25, 2020, but the prompt does not provide the vote count or opinion lineup.
Impact
The answer can decide who gets millions of dollars when related companies, banks, or creditors all claim the same refund. For example, a failed parent company and one of its subsidiaries may each say the IRS payment belongs to them.
What's next
The Supreme Court has finished this docket action. The lower courts and the parties must now apply the Court's decision in the underlying refund dispute.
What was the core dispute in Rodriguez v. FDIC?
The fight was over who owned a tax refund paid to a corporate group. The Court was asked whether judges should use the Bob Richards rule or state law.
Why does Rodriguez v. FDIC matter in the real world?
It matters when affiliated companies collapse or enter bankruptcy and a tax refund becomes valuable property. Creditors, regulators, and subsidiaries may all want the money.
What happens next after the Supreme Court's action in Rodriguez v. FDIC?
The Supreme Court's work in this case is done. The lower courts and parties must carry out that decision in the remaining dispute over the refund.
Decision
What the Court decided
This case resolved the legal rule for deciding who owns a corporate group's tax refund when the parent receives the check but a subsidiary's losses produced it.
Impact
The answer can decide who gets millions of dollars when related companies, banks, or creditors all claim the same refund. For example, a failed parent company and one of its subsidiaries may each say the IRS payment belongs to them.
Not official Court text.
Opinion documents
Related cases




Grounding
- Grounding
- Primary materials plus reporting.
- Note
- Best-effort analysis: this explainer relies on a mix of primary materials and trusted secondary sources. Official filings and opinions remain authoritative.
- Checked
- Jul 2, 2026
- Method
- Methodology
Primary materials10
Supreme Court docket 18-1269
docket | Jul 3, 2026
Primary case document
Supreme Court document | Jul 3, 2026
CourtListener docket record
docket | Jul 3, 2026
Questions Presented
brief | May 25, 2026
opinion
opinion | Feb 25, 2020
Petition
brief | Apr 1, 2019
SupremeCourt.gov
official | Jul 2, 2026
SupremeCourt.gov
official | Jul 2, 2026
SupremeCourt.gov
official | Jul 2, 2026
SupremeCourt.gov
official | Jul 2, 2026