Independent Bankers Ass'n of America v. Smith

Opinion for the Court filed by Circuit Judge WILKEY.

WILKEY, Circuit Judge: *

This is an appeal by the Comptroller of the Currency from a judgment of the United States District Court for the District of Columbia (Robinson, J.) declaring unlawful and enjoining an interpretive ruling of the Comptroller relating to the use of electronic funds transfer systems by national banks.1 Appellant Comptroller challenges the district court’s memorandum and order by arguing (1) that plaintiffs’ challenge to his interpretive ruling is not ripe for judicial resolution, (2) that, in any event, he correctly…