Campbell v. Federal Deposit Insurance, 676 F.3d 615

FIRREA governs claim filing and requires administrative exhaustion before court action.
FDIC as receiver published a 90-day bar date for claims (Oct. 7, 2009).
Trustee discovered potential claim when the insurer surrendered policy value to FDIC (Sept. 24, 2009).
Trustee did not file a proof of claim by the bar date and later sought relief under the FIRREA exception.
Trustee argued the claim related to a policy assigned to the Bank as collateral and involved premiums paid by the Bank.
FDIC denied the claim as time-barred; district court dismissed for lack of jurisdiction.

Issue	Plaintiff's Argument	Defendant's Argument	Held
Whether 12-day notice provides a meaningful filing opportunity.	Campbell argues exception may apply for late notice.	FDIC argues claim arose but filed after bar date; no exception.	No meaningful opportunity; exception not applicable.
Whether the claim arose within the 90-day post-receivership window qualifies for extension.	Trustee claims due process requires extension.	No authority to extend for post-window claims.	Not applicable; no post-window claim.
Whether due process requires extending FIRREA when notice is near the bar date.	Trustee asserts potential due process concerns.	No near-midnight discovery scenario present.	Due process not satisfied to grant extension.
Whether equal protection arguments salvage the claim.	Trustee asserts unequal treatment of pre/post-bar claims.	Different treatment has rational basis.	Equal protection claim rejected.

Carlyle Towers Condo. Ass'n v. FDIC, 170 F.3d 301 (2d Cir.1999) (extensions granted only for post-bar-date claims; arose after bar date)
Elmco Props., Inc. v. Second Nat'l Sav. Ass'n, 94 F.3d 914 (4th Cir.1996) (due process and notice issues in FIRREA contexts)
Althouse v. RTC, 969 F.2d 1544 (3d Cir.1992) (near-bar-date notice scenarios raise due process concerns)
Stamm v. Paul, 121 F.3d 635 (11th Cir.1997) (strict interpretation of bar date in FIRREA)