Fed. Home Loan Bank of Bost v. Moody's Corp., No. 14-2148 (1st Cir. 2016)Annotate this Case
In 2011, Federal Home Loan Bank of Boston (Bank), a federally-chartered entity pursuant to 12 U.S.C. 1432(a), filed suit against multiple defendants, including Moody’s Corporation and Moody’s Investors Service, Inc. (collectively, Moody’s), in Massachusetts state court alleging that various rating agencies falsely gave out triple-A ratings to mortgage-backed securities that were riskier than indicated by their ratings. Some of the defendants, but not Moody’s, removed the case to the Massachusetts federal district court on the grounds that the Bank was federally chartered. Moody’s then moved to dismiss on the ground that the Massachusetts district court lacked personal jurisdiction over it. The district judge ultimately granted the motion, concluding that personal jurisdiction was lacking after Daimler AG v. Bauman, and entered separate and final judgment in favor of Moody’s. The district judge also denied the Bank’s motion to sever its claims against Moody’s from those against the other defendants and transfer them to the Southern District of New York. The First Circuit vacated the district court’s dismissal order, holding that the district court erred in concluding that it lacked statutory power to transfer the claims against Moody’s to the Southern District of New York. Remanded.
The court issued a subsequent related opinion or order on May 6, 2016.