On June 6th, a U.S. District Court held that Section 215a of the National Bank Act does not preempt state law tort and securities fraud claims brought by a bank's minority shareholders. The shareholders alleged they were squeezed out by defendants in a merger and reorganization. Defendants moved to dismiss, arguing that Section 215a preempted the state law claims. The Court, however, found that the state laws do not stand as an obstacle to the accomplishment and execution of Section 215a's purpose, which is to simplify the merger of national bank associations. The Court further found that the shareholders adequately pleaded violations of the federal securities laws. Beatty v. JRMB II, Inc.