City of Miami v. Wells Fargo & Co., 923 F.3d 1260 (2019)

Citation: City of Miami v. Wells Fargo & Co., 923 F.3d 1260 (2019)
Parent Document: City of Miami v. Wells Fargo & Co., 923 F.3d 1260 (2019)
Jurisdiction: United States (federal)
Effective Date: 2019-05-03
Original Source: https://www.courtlistener.com/opinion/4616452/city-of-miami-v-wells-fargo-co/ ↗

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  We also reject the application of Anza v. Ideal Steel Supply Corp, 547 U.S. 451, 457 (2006),
that Wells Fargo has offered in its briefing on remand. It cites Anza for its proposed rule that
proximate cause cannot exist where the causes of a plaintiff’s injury are distinct from the
violative conduct. But this amounts to simply assuming the answer to our question. Whether the
causes of the City’s injury are too distinct and too remote from the violative conduct is at the
heart of the proximate cause inquiry. Furthermore, the Bank’s suggested rule overlooks that
Anza applied the factors drawn from Holmes. Anza, 547 U.S. at 459–60.

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