The Fifth Circuit Court of Appeals has determined that the unclaimed funds of Texas residents from an antitrust settlement reached in 1999 must be placed in the custody of the state under an unclaimed property statute and that a federal court could not distribute the funds under the cy pres doctrine. All Plaintiffs v. All Defendants, No. 10-40119 (5th Cir., decided June 27, 2011). At issue was some $10 million in unclaimed funds of which $4 million had been allocated to plaintiffs whose last known addresses were in Texas. The court determined that “the question of who shall have a property right in the unclaimed funds is substantive,” and thus, funds allocated to plaintiffs with a last known address in Texas were governed by the Texas Unclaimed Property Act.