In Atherton v. FDIC, 519 U.S. 213 (1997), the Supreme Court construed FIRREA's requirements (The Financial Institutions Reform, Recovery, and Enforcement Act of 1989) and held that "state law sets the standard of conduct as long as the state standard (such as simple negligence) is stricter than that of the federal statute. The federal statute nonetheless sets a `gross negligence' floor, which applies as a substitute for state standards that are more relaxed." 519 U.S. at 216.