FDIC, as receiver for R-G Prem v. Estrada-Rivera, 722 F.3d 50

Estrada-Rivera signed a $700,000 line of credit with R-G Premier Bank of Puerto Rico for EER-IPR.
The Bank was later taken over by the FDIC as receiver and the action was removed to federal court.
Appellants alleged the Bank breached a financing agreement with ECC and with appellants themselves, causing the default and seeking at least $50 million in damages.
The district court granted summary judgment for the FDIC on the collection action, finding the debt due and payable and no written condition tying repayment to ECC financing.
The district court dismissed the counterclaim for lack of subject-matter jurisdiction under 12 U.S.C. § 1821(d)(6), (d)(13)(D) after FDIC disallowed the claim.

Issue	Plaintiff's Argument	Defendant's Argument	Held
Whether the FDIC collection judgment was proper despite alleged Bank repudiation	Estrada-Rivera argues Bank’s breach should excuse payment.	FDIC contends no written condition creates a defense under § 1823(e)(1).	Summary judgment proper; no written condition evidenced.
Whether the counterclaim was properly dismissed for lack of jurisdiction	Appellants claim proper administrative procedures were met and claims should proceed.	FDIC no-value determination and prudential mootness preclude relief.	District court's dismissal affirmed; no redressable claim.

Beal Bank, SSB v. Pittorino, 177 F.3d 65 (1st Cir. 1999) (1823(e) prevents unwritten agreements as defense to FDIC assets)
LeBlanc v. FDIC, 85 F.3d 821 (1st Cir. 1996) (D'Oench doctrine applied; prevents unrecorded understandings as defenses)
D'Oench, Duhme & Co. v. FDIC, 315 U.S. 447 (S. Ct. 1942) (establishing D'Oench doctrine)
McCullough v. FDIC, 987 F.2d 870 (1st Cir. 1993) (1823(e) described as statutory partner of D'Oench)
Acosta-Ramírez v. Banco Popular de P.R., 712 F.3d 14 (1st Cir. 2013) (administrative claims process requirements)
FDIC v. Kooyomjian, 220 F.3d 10 (1st Cir. 2000) (no-value determinations preclude relief)