Sea-Land Service, Inc. v. United States

How later courts describe this case

• noting that the federal interest underlying the IGBA is the eradication of large-scale gaming
• prosecutor’s reference to defendant taking advantage of children at Christmas was improper appeal to emotion
• “Because § 1823(e) is merely a codification of D’Oench and its progeny, defenses premised upon § 1823(e) are usually construed in tandem.”
• “If the FDIC could satisfy state law holder in due course requirements, there would be no reason to invoke federal common law * * *.”
• in case involving multiple false statement charges jury must be given special unanimity instruction
• two documents in bank file insufficient to show bank’s obligation to transfer the additional property where one memorandum vaguely alluded to possibility of transfer and letter mentioned only “amendment to mortgage”
• rejecting Hinton’s per se rule of dismissal