County of Oakland v. Federal Housing Finance Agency

OPINION

McKEAGUE, Circuit Judge.

The State and County plaintiffs sued the Federal National Mortgage Association (Fannie Mae), the Federal Home Loan Mortgage Corporation (Freddie Mac), and the Federal Housing and Finance Agency in an effort to collect state and local real estate transfer taxes that plaintiffs claim are owed for real property transfers made by defendants. Congress expressly exempted all three defendants from “all [state and local] taxation.” In an effort to get around the plain language of the exemption statutes, plaintiffs argue that when Congress exempted' the defendants from…