SVB Financial Trust v. Federal Deposit Insurance Corporation

Background

The court had related two actions brought by SVB Financial Trust. The first action is against the Federal Deposit Insurance Corporation in its corporate capacity. The second is against the Federal Deposit Insurance Corporation as receiver for Silicon Valley Bank and Silicon Valley Bridge Bank, N.A. Both actions were assigned to Judge Beth Labson Freeman. The court had already ordered coordinated discovery and set hearings on summary-judgment motions for February 5, 2026.

The Trust moved to consolidate the two actions. The FDIC in its corporate capacity and the FDIC as receiver opposed the motion. The court decided the motion without oral argument and vacated the hearing scheduled for May 1, 2025. The court stated that the separate hearing on the Trust’s motion to strike would remain scheduled for that date.

Legal standard

Federal Rule of Civil Procedure 42(a)(2) allows a court to consolidate actions that involve a common question of law or fact. The court explained that district courts have broad discretion to consolidate cases pending in the same district. In exercising that discretion, the court weighs judicial convenience against possible delay, confusion, and prejudice.

Court’s reasoning

The court found that the two actions present similar factual and legal issues. Both arise from the same series of events and are based on the same alleged wrongful conduct. In both cases, the Trust alleges that the FDIC lacked authority to deny the Trust access to its deposits, called the “Account Funds,” at Silicon Valley Bank after the invocation of the Systemic Risk Exception following the bank’s collapse. Both cases seek access to those Account Funds.

Because the actions arise from the same core facts, involve overlapping factual and legal issues, and seek similar remedies, the court concluded that consolidation would conserve judicial resources, reduce confusion, and reduce the time and cost of trying the cases separately.

Order

Judge Beth Labson Freeman GRANTED the Trust’s motion to consolidate the two actions for all purposes under Rule 42(a). The court ordered that no consolidated complaint be filed and that both actions remain open. The parties must continue filing documents separately in each case. The court reset the pretrial conference in the consolidated action for May 7, 2026, at 1:30 p.m. Pacific Time, and set trial to begin July 13, 2026.

This order addressed case management and consolidation; it did not decide the parties’ underlying dispute over access to the Account Funds.