McClaine v. Rankin

Background

A bank receiver and creditors sued a former shareholder to collect an assessment the Comptroller of the Currency ordered after a national bank failed. The suit was filed within three years of the assessment but after two years had passed. The parties disputed which Washington statute of limitations period applied.

Reasoning

The core question was whether the shareholder’s obligation to pay the assessment is treated as a contract claim or as a statutory liability for state time limits. The Court concluded the liability is conditional and arises from the federal statute and the Comptroller’s assessment, not from a written contract. Because the right to sue did not exist until the Comptroller acted, the Court held Washington’s two-year catchall limitation applied rather than the three-year rule for nonwritten contracts. The Court reversed the Circuit Court of Appeals and directed judgment for the defendant on statute-of-limitations grounds.

Real world impact

The decision affects attempts to collect national-bank assessments from shareholders. Where state law has a shorter general limit, such suits can be time-barred if not brought within that period after the Comptroller’s assessment. This is a ruling about timing and procedure, not about whether shareholders owe the assessment in the first place.

Dissents or concurrances

Three Justices dissented, arguing prior decisions treat the stockholder liability as contractual and thus covered by the longer three-year limitation; they warned the majority’s view departs from earlier federal rulings.