In re Louisiana Bank & Trust Co.

590 So. 2d 667, 1991 La. App. LEXIS 2937, 1991 WL 236322
CourtLouisiana Court of Appeal
DecidedNovember 13, 1991
DocketNo. 90-522
StatusPublished

This text of 590 So. 2d 667 (In re Louisiana Bank & Trust Co.) is published on Counsel Stack Legal Research, covering Louisiana Court of Appeal primary law. Counsel Stack provides free access to over 12 million legal documents including statutes, case law, regulations, and constitutions.

Bluebook
In re Louisiana Bank & Trust Co., 590 So. 2d 667, 1991 La. App. LEXIS 2937, 1991 WL 236322 (La. Ct. App. 1991).

Opinion

GUIDRY, Judge.

The Commissioner of Financial Institutions of the State of Louisiana was confirmed by the court as conservator of the Louisiana Bank and Trust Company of Crowley, Louisiana (hereafter LBT) on December 10, 1987. By a separate order on that same day, the bank was closed, liquidation of LBT was commenced and the Federal Deposit Insurance Corporation (hereafter FDIC) was named receiver.

On April 15, 1988, appellant, Edmund M. Reggie, timely filed two proofs of claims against LBT with the Receiver, representing alleged cash advances made by him on behalf of LBT and mineral rights/royalties allegedly held in the name of LBT for account of Reggie. The FDIC allegedly rejected both of these claims, notifying appellant of said “rejection” by letter dated November 10,1988. Subsequently, on February 6, 1989, appellant petitioned the receivership court seeking a hearing on the rejection of his claims. In response, the FDIC filed exceptions of no cause of action and no right of action urging that Reggie’s suit was untimely. The trial court sustained the Receiver’s exceptions and dismissed Reggie’s suit. Reggie appealed.

La.R.S. 6:393 provides as follows:

“A. All persons having claims against the bank shall present their claims substantiated by legal proof to the receiver within one hundred eighty days after the bank is closed.
B. The receiver shall cause notice of the claims procedure to be published once a week for twelve consecutive weeks in a newspaper of general circulation in the parish of domicile of the bank and to be mailed to each person whose name appears as a creditor or depositor upon books of the bank at his last address of record.
C. Within one hundred eighty days following receipt of the claim, the receiver shall notify in writing any claimant whose claim has been rejected. Notice is effective when mailed. Any claimant whose claim has been rejected by the receiver may petition the receivership court for a hearing on his claim within sixty days from the date his claim is rejected.”

The following sequence of events, which give rise to this suit, are undisputed:

[669]*6691. LBT closed on December 10, 1987.
2. Appellant timely filed two Proofs of Claims on April 15, 1988.
3. By letter dated November 10, 1988, 25 days beyond the statutorily prescribed period, the FDIC notified Reggie that his claims had been rejected.1
4. Reggie filed this suit on February 10, 1989, 92 days after the FDIC rejected his claims.

FDIC’S UNTIMELY REJECTION

Appellant first argues that the FDIC’s untimely rejection of his proofs of claims constituted an implied acceptance of same. We find no merit in this argument.

Appellant cites no authority in support of this contention other than the fact that La.R.S. 6:393(C) uses the word “shall”. It is well settled that the word “shall” is mandatory. La.R.S. 1:3; La.C.C.P. art. 5053.

La.R.S. 6:393, by use of the word “shall”, mandates that claimants file any proofs of claims against a failed bank and that the receiver notify, in writing, any claimant whose claim has been rejected within 180 day periods. The statute is silent, however, as to the consequences of either’s failure to comply with such mandates.

In Hayden v. Richland Parish School Board, 554 So2d 164 (La.App. 2d Cir.1989), writ denied, 559 So.2d 124 (La.1990), our brethren of the Second Circuit stated:

“The rules of statutory construction provide that where two statutes deal with the same subject matter, they should be harmonized if possible but if there is a conflict, the statute specifically directed to the matter at issue must prevail as an exception to the statute more general in character. The jurisprudence is uniform that all statutory provisions are to be given effect whenever possible. If statutes can be reconciled by a fair and reasonable interpretation, it must be done, as the repeal of a statute by implication is not favored nor to be indulged in if there is any other reasonable construction.
The construction of a particular statute which creates a statutory inconsistency should be avoided when an interpretation can be adopted which will not do violence to the plain words of an act. The legislature is presumed to have enacted each statute with deliberation and with full knowledge of all existing laws on the same subject. The meaning and intent of the statutory provision, therefore, is to be determined by a consideration of the statute in its entirety and all other laws on the same subject matter and a construction should be placed on the provision in question which is consistent with the express terms of the statute and with the obvious intent of the legislature in enacting it. ...” (footnotes omitted)

As stated earlier, R.S. 6:393 provides no penalty or consequence for failure of a party to meet the statutorily mandated 180 day periods. However, R.S. 6:394 contemplates the filing and consideration of claims after the 180 day period.

The statute provides:

“All claims filed after the one hundred eighty day claim period prescribed by R.S. 6:393 and subsequently accepted by the receiver or allowed by the receivership court shall be entitled to share in the distribution of assets only to the extent of the undistributed assets in the hands of the receiver on the date such claims are accepted or allowed.”

Clearly, R.S. 6:394 contemplates the filing and consideration of proofs of claims after the 180 day period and to such extent is seemingly in conflict with the provisions of R.S. 6:393.. We believe that the seeming conflict can be reconciled by a fair and reasonable interpretation of the statutory provisions. If the legislature had intended the belated rejection of a claim to constitute an acceptance, as appellant suggests, the statute would have so provided. There [670]*670is no provision in the statute which even suggests this legislative intent.

We interpret the statute’s mandate in limiting the periods for filing and acceptance or rejection of claims as relating only to the fund or assets against which the claim may be leveled and the time when the receivership court may be petitioned. As we interpret the statutory provision, a proof of claim, when timely filed, if ultimately accepted within or beyond the mandated 180 days, is entitled to share in the distribution of assets available as of the date of the bank’s closure. On the other hand, if a claim is untimely filed but subsequently accepted or allowed by the receivership court, the claim shares in the distribution of assets but only to the extent of the undistributed assets in the hands of the receiver on the date such claims are accepted or allowed. Another consequence of a belated notification of rejection would be a delay in the commencement of the 60 day period for filing for judicial review of a rejected claim. Additionally, in our view, the failure of the Receiver to reject a claim within the mandated period would permit the institution of proceedings in the receivership court after such period, albeit the 60 day period limiting a claimant’s right to institute such proceedings does not commence until final rejection.

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590 So. 2d 667, 1991 La. App. LEXIS 2937, 1991 WL 236322, Counsel Stack Legal Research, https://law.counselstack.com/opinion/in-re-louisiana-bank-trust-co-lactapp-1991.