Ledwidge v. Federal Deposit Insurance Corporation

CourtDistrict Court, District of Columbia
DecidedMay 12, 2026
DocketCivil Action No. 2024-0513
StatusPublished

This text of Ledwidge v. Federal Deposit Insurance Corporation (Ledwidge v. Federal Deposit Insurance Corporation) is published on Counsel Stack Legal Research, covering District Court, District of Columbia primary law. Counsel Stack provides free access to over 12 million legal documents including statutes, case law, regulations, and constitutions.

Bluebook
Ledwidge v. Federal Deposit Insurance Corporation, (D.D.C. 2026).

Opinion

UNITED STATES DISTRICT COURT FOR THE DISTRICT OF COLUMBIA

_________________________________________ ) NIALL LEDWIDGE, et al., ) ) Plaintiffs, ) ) v. ) Case No. 24-cv-00513 (APM) ) FEDERAL DEPOSIT INSURANCE ) CORPORATION, et al., ) ) Defendants. ) _________________________________________ )

MEMORANDUM OPINION

I.

Plaintiffs Niall Ledwidge, Andrew Childe, and Michael Pearson, the Joint Official

Liquidators (“Liquidators” or “JOLs”) of the Cayman Islands Branch of the now-defunct Silicon

Valley Bank or SVB (“Cayman Branch” or “SVB Cayman”), bring this suit against the Federal

Deposit Insurance Corporation (FDIC) and several of its officials.1 Liquidators allege that

Defendants improperly denied “insured deposit” status to Cayman Branch depositors following

SVB’s collapse.

Before the court are both Defendant FDIC’s Motion to Dismiss the Amended Complaint,

ECF No. 12, and the Individual Defendants’ Motion to Dismiss Due Process Claim (Count VIII),

ECF No. 15. Because Plaintiffs lack standing, the court grants both motions.

1 Silicon Valley Bank itself is also listed as a plaintiff. But as this opinion will explain, only the FDIC—not Liquidators—can bring claims on behalf of SVB. II.

The factual background of this case is detailed in related decisions. See In re SVB Fin.

Grp., 674 B.R. 111 (Bankr. S.D.N.Y. 2025); Ledwidge v. FDIC, No. 5:24-cv-08352-BLF, 2025

WL 3454837 (N.D. Cal. Dec. 1, 2025). The court incorporates those facts by reference here.

In brief, after SVB collapsed, the FDIC was appointed receiver and assumed “all SVB

assets and liabilities.” Ledwidge, 2025 WL 3454837, at *1. Eventually, the FDIC sent notice to

some of SVB’s Cayman Branch depositors “that their balances were not deposits” as defined by

the Federal Deposit Insurance Act, “and therefore their status was that of general unsecured

creditors junior to both insured and uninsured depositors (and thus they were unlikely to receive

any recovery from the SVB receivership).” In re SVB Fin. Grp., 674 B.R. at 123. Liquidators

object to this determination.

Liquidators point to a “Winding-Up Order” issued by the Grand Court of the Cayman

Islands as the source of their authority to bring this action. Am Compl., ECF No. 4 [hereinafter

Am. Compl.], Ex. 2, ECF No. 4-2 [hereinafter Winding-Up Order]. In that order, the court

appointed Ledwidge, Childe, and Pearson as Joint Official Liquidators for the purpose of winding

up SVB’s activities in the Cayman Islands. Id. The order provided that their “powers shall be

limited to acting in respect of the assets and affairs of the Cayman Islands branch of [SVB] and its

creditors.” Id. at 2.

III.

The primary issue in this case is one of standing, as to which the Liquidators bear the

burden. Arpaio v. Obama, 797 F.3d 11, 19 (D.C. Cir. 2015). At this stage, the court will “accept

the well-pleaded factual allegations as true and draw all reasonable inferences from those

allegations in [their] favor.” Id. The court will not, however, “assume the truth of legal

2 conclusions” or “accept inferences that are unsupported by facts set out in the complaint.” Id.

(internal quotation marks omitted).

Liquidators advance two theories of standing. They assert that, pursuant to the Winding-

Up Order, they “have standing to bring claims directly on behalf of SVB Cayman and to bring

claims as the exclusive agent of all depositors-creditors of SVB Cayman.” Am Compl. ¶ 5. Both

theories fail.

On behalf of SVB Cayman. When the FDIC was appointed SVB’s receiver, it “succeed[ed]

to . . . all rights, titles, powers, and privileges of the insured depository institution.” 12 U.S.C.

§ 1821(d)(2)(A)(i). The FDIC is therefore the only entity that may sue to directly assert SVB’s

rights. Those rights include those that might derive from the Cayman Branch, which Liquidators

concede was part of SVB rather than a separately incorporated entity. See Pls.’ Mem. of L. in

Opp’n to Defs.’ Mots. to Dismiss, ECF No. 31 [hereinafter Pls.’ Opp’n], at 4 n.3. Liquidators thus

lack standing to sue on behalf of SVB Cayman. See Ledwidge, 2025 WL 3454837, at *3.

Liquidators primarily counter that claims against the FDIC for misconduct as receiver are

“routinely recoverable.” Pls.’ Opp’n at 36. But neither of the cases on which Liquidators rely

involved plaintiffs attempting to sue on behalf of the entity for which the FDIC had become the

receiver. See id. at 36–37 (first citing Lopez-Flores v. Resolution Tr. Corp., 93 F. Supp. 2d 834

(E.D. Mich. 2000); then citing Homeland Stores, Inc. v. Resolution Tr. Corp., 17 F.3d 1269 (10th

Cir. 1994)). Liquidators also emphasize the nature of their claims as a reason to confer standing

to sue on behalf of SVB. They highlight the “extraordinary actions of the Defendants” and the

“Cayman-centric issues at the heart of this case.” See id. at 35, 37–38. And they assert that “it is

a temporal and legal impossibility” for the FDIC to have succeeded to their “Clawback Claims,”

which “are solely available to joint official liquidators” and did not arise until after the FDIC was

3 appointed receiver. Id. at 38. But neither the characteristics of the claims nor the time at which

they arose change the unambiguous statutory language dictating that the FDIC succeeds to “all”

of SVB’s rights.2 See In re Grand Jury Subpoena, 912 F.3d 623, 628 (D.C. Cir. 2019) (per curiam)

(explaining that “all” means “all”). Accordingly, only the FDIC—not Liquidators—has standing

to assert them.

On behalf of depositors. As to their agency theory, Liquidators are collaterally estopped

from asserting it. Collateral estoppel prevents parties from relitigating issues that have been

(1) “contested by the parties and submitted for judicial determination in [a] prior case” and

(2) “actually and necessarily determined by a court of competent jurisdiction in that prior case.”

Aenergy, S.A. v. Republic of Angola, 123 F.4th 1351, 1356 (D.C. Cir. 2024) (quoting In re

Subpoena Duces Tecum Issued to Commodity Futures Trading Comm’n, 439 F.3d 740, 743

(D.C. Cir. 2006)). Preclusion also “must not work a basic unfairness to the party bound by the

first determination.” Id. The doctrine applies to “questions of jurisdiction” like standing. Cutler v.

Hayes, 818 F.2d 879, 888 (D.C. Cir. 1987). In fact, “[a] valid jurisdictional judgment has

preclusive effect . . . even if erroneous.” Id.

On the first requirement, Liquidators have submitted this issue for prior judicial

determination not once, but twice. See Notice of Suppl. Authority, ECF No. 42; Notice of Suppl.

Authority, ECF No. 43. Before the Bankruptcy Court in the Southern District of New York,

Liquidators asserted that they had standing “pursuant to the ordinary tenets of agency law in the

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Related

Montana v. United States
440 U.S. 147 (Supreme Court, 1979)
Powers v. Ohio
499 U.S. 400 (Supreme Court, 1991)
Lopez-Flores v. Resolution Trust Corp.
93 F. Supp. 2d 834 (E.D. Michigan, 2000)
Steel Co. v. Citizens for a Better Environment
523 U.S. 83 (Supreme Court, 1998)
Joseph Arpaio v. Barack Obama
797 F.3d 11 (D.C. Circuit, 2015)
Swanson Group Mfg. LLC v. Jewell
195 F. Supp. 3d 66 (District of Columbia, 2016)
In re: Grand Jury Subpoena
912 F.3d 623 (D.C. Circuit, 2019)
Perry Capital LLC v. Mnuchin
864 F.3d 591 (D.C. Circuit, 2017)
Aenergy, S.A. v. Republic of Angola
123 F.4th 1351 (D.C. Circuit, 2024)

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