Any action under this section may be brought in any United States district court, or in any other court of competent jurisdiction, within one year after the date of the occurrence of the violation involved.
Petitioner bank sued respondent bank in federal district court alleging that respondent had failed to comply with it obligations under the Expiated Funds Availability Act (Act), 12 U.S.C.S. §§ 4001-4010. Petitioner alleged that respondent had not acted with ordinary care when it returned a check for guarantee of endorsement without first checking the sufficiency of the funds in support of the check. The district court found in favor of petitioner, finding respondent negligent in not notifying petitioner of the insufficient funds problem the first time it returned the check. The court of appeals, not reaching the merits, vacated the judgment of the district court and ordered that the action be dismissed for lack of jurisdiction. The court reversed the judgment of the court of appeals that found that the district court did not have subject-matter jurisdiction over the action by petitioner bank against respondent bank.
Did the Court of Appeals err when it ordered dismissal of the action for lack of jurisdiction?
The Expedited Funds Availability Act provided for federal court jurisdiction, not only in suits between customers and banks, but also in cases initiated by one bank against another bank.