Rodriguez v. FDIC
In brief
The Court rejected the federal Bob Richards rule, wiped out the Tenth Circuit’s judgment, and sent the refund dispute back for another look.
- Where it stands
- Decided
Decided 9-0 · February 25, 2020 · Opinion by Justice Gorsuch
- What it’s about
- The Supreme Court ruled that the federal “Bob Richards” rule cannot decide who owns a tax refund paid to an affiliated corporate group because no uniquely federal interest justifies it.
- Who it affects
- The decision says federal courts may not use Bob Richards, a judge-made federal rule, to decide this ownership dispute. The lower court must continue the case, and the Supreme Court did not decide who ultimately gets this refund.
Summary: written with AI from the case record.
What it's about
It wiped out the Tenth Circuit’s ruling and sent Rodriguez’s dispute with the FDIC back for further proceedings (vacated and remanded), without deciding who ultimately owns the refund.
The case addressed when federal courts may create judge-made rules instead of applying a state’s ordinary 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.
What the Court decided
Holding
The Bob Richards rule is not a legitimate exercise of federal common lawmaking. Federal judges may appropriately craft the rule of decision in only limited areas, Sosa v. Alvarez-Machain, 542 U. S. 692, 729, and claiming a new area is subject to strict conditions. One of the most basic is that federal common lawmaking must be “ ‘necessary to protect uniquely federal interests.’ ” Texas Industries, Inc. v. Radcliff Materials, Inc., 451 U. S. 630, 640. The Bob Richards rule has not satisfied this condition. The federal courts applying and extending Bob Richards have not pointed to any significant federal interest sufficient to support the Bob Richards rule. Nor have the parties in this case. 914 F. 3d 1262, vacated and remanded.
- Result
- Vacated
The vote
What's next
The Tenth Circuit will handle further proceedings after the Supreme Court wiped out its judgment and sent the case back (vacated and remanded). Who ultimately owns the refund remains unresolved.
Documents
Docket activity
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AI analysis generated: Opinion Summary
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More questions
- What was Rodriguez v. FDIC about?
- It concerned whether the parent or subsidiary owns a federal tax refund, and whether federal judge-made law or state law supplies the rule.
- What did the Supreme Court do in Rodriguez v. FDIC?
- It rejected Bob Richards as a federal rule, wiped out the Tenth Circuit’s judgment, and sent the case back (vacated and remanded).
- What remains unresolved after the ruling?
- The Supreme Court did not decide who ultimately owns the refund; the lower court must continue the case.
- What happens next in Rodriguez v. FDIC?
- The Tenth Circuit will handle further proceedings after the Supreme Court sent the case back (remanded it). Ownership of the refund remains open.
Sources
Primary materials plus reporting. Best-effort analysis: this explainer relies on a mix of primary materials and trusted secondary sources. Official filings and opinions remain authoritative.