Jeanne Patterson v. Federal Deposit Insurance Corporation

BARKSDALE, Circuit Judge:

This appeal concerns primarily whether 12 U.S.C. § 1823(e) precludes Patterson from offering evidence in support of her homestead claim as a defense against foreclosure by the Federal Deposit Insurance Corporation (FDIC) when: (1) her homestead claim is not based on an agreement, but instead arises under the Texas Constitution and statutes exempting its citizens from forced sale of their homesteads; but (2) the evidence offered is, in part, contrary to her homestead disclaimer in the deed(s) of trust in issue. Because the district court erred in excluding such…