On April 26th, the Eleventh Circuit held that the anti-injunction provision of the Financial Institutions Reform, Recovery and Enforcement Act prohibits a federal district court from enjoining the FDIC. A trial court had initially imposed a TRO against a failing bank prohibiting it from taking any action with respect to $1 billion worth of mortgage proceeds it held in trust for petitioner, Bank of America, who held legal title. When the FDIC was appointed receiver, the FDIC moved to dissolve the TRO. The trial court refused converting the TRO into a preliminary injunction. The Eleventh Circuit dissolved the injunction holding that FIRREA bars district courts from enjoining the FDIC from exercising its receivership powers. The fact that the disputed assets were allegedly held in a custodial fashion did not change the result. Bank of America v. Colonial Bank.