SUMMARIES OF LANDMARK JUDGMENTS OF THE USA SUPREME COURT ON BANKRUPTCY
CONSTITUTIONAL CHALLENGES
STURGES V. CROWNINSHIELD
The Supreme Court in Sturges v. Crowninshield, 17 U.S. (4 Wheat.) 122 (1819) held that states do have the power to enact bankruptcy and insolvency laws, provided that Congress has not enacted a conflicting federal bankruptcy law. However, the Court also held that such state laws cannot be applied to discharge debts arising from contracts entered into before the enactment of the law, as this would impair the obligation of contracts and therefore violate the Constitution.
OGDEN V. SAUNDERS
The Supreme Court in Ogden v. Saunders, 25 U.S. (12 Wheat.) 213 (1827) held that state insolvency laws are constitutional when applied to contracts made after the enactment of the law, provided the law is part of the contract’s legal context. However, such laws cannot impair the obligation of contracts that were formed before the law came into existence.
HANOVER NATIONAL BANK V. MOYSES
The Supreme Court in Hanover National Bank v. Moyses, 186 U.S. 181 (1902) upheld the Bankruptcy Act of 1898 and ruled that it was constitutional. The Court held that Congress has broad authority to enact bankruptcy laws and may incorporate state exemption laws without violating the constitutional requirement of uniformity.
WRIGHT V. VINTON BRANCH OF MOUNTAIN TRUST BANK
The Supreme Court in Wright v. Vinton Branch of Mountain Trust Bank, 300 U.S. 440 (1937) upheld most of the amended Frazier-Lemke Act, holding that Congress acted within its bankruptcy powers. However, the Court emphasized that bankruptcy legislation must provide fair treatment to secured creditors and cannot arbitrarily strip them of their property rights.
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KUEHNER V. IRVING TRUST CO
The Supreme Court in Kuehner v. Irving Trust Co. 299 U.S. 445 (1937) upheld the constitutionality of provision enacted by Congress providing statutory limitation on landlord claim for damages arising from lease rejection.
NORTHERN PIPELINE CONSTRUCTION CO. V. MARATHON PIPE LINE CO.
The Supreme Court in Northern Pipeline Construction Co. v. Marathon Pipe Line Co., 458 U.S. 50 (1982) held that the Bankruptcy Act of 1978 unconstitutionally vested Article III judicial power in bankruptcy judges who lacked Article III protections. The broad grant of jurisdiction to bankruptcy courts violated the separation of powers embodied in Article III.
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KATCHEN V. LANDY
The Supreme Court in Katchen v. Landy 382 U.S. 323 (1966) held that a creditor who files a proof of claim submits to the bankruptcy court’s equitable jurisdiction and is not entitled to a jury trial on issues that must be resolved in the process of allowing or disallowing that claim.
GRANFINANCIERA, S.A. V. NORDBERG
The Supreme Court in Granfinanciera, S.A. v. Nordberg 492 U.S. 33 (1989) held that the Seventh Amendment preserves the right to a jury trial in cases were defendant has not filed claim before bankruptcy trustee. Congress cannot eliminate that right merely by labelling the action a “core proceeding” under the Bankruptcy Code.
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LANGENKAMP V. CULP
The Supreme Court in Langenkamp v. Culp 498 U.S. 42 (1990) held that creditors who file claims against the bankruptcy estate are not entitled to a jury trial in preference actions brought by the trustee.
STERN V. MARSHALL
The Supreme Court in Stern Vs Marshall held that Bankruptcy Court does not have jurisdiction to enter a final judgment on a state-law claim involving private rights, when that claim is not necessarily resolved in the process of adjudicating a creditor’s proof of claim, even if Congress has designated the matter as a “core proceeding.
EXECUTIVE BENEFITS INSURANCE AGENCY V. ARKISON
The Supreme Court in Executive Benefits Insurance Agency v. Arkison 573 U.S. 25 (2014) held that when a bankruptcy court encounters a so-called Stern claim, it may treat the matter as a non-core proceeding and issue proposed findings of fact and conclusions of law for de novo review by the district court.
WELLNESS INTERNATIONAL NETWORK LTD. V. SHARIF
The Supreme Court in Wellness International Network Ltd. Vs Sharif 575 U.S. 665 (2015) held that Article III is not violated when parties knowingly and voluntarily consent to adjudication by a bankruptcy judge. Such consent allows the bankruptcy court to enter a final judgment even on matters that otherwise could not constitutionally be finally decided by a bankruptcy court.
RAILWAY LABOR EXECUTIVES’ ASSOCIATION V. GIBBONS
The Supreme Court in Railway Labor Executives’ Association v. Gibbons 455 U.S. 457 (1982) held that the Rock Island Railroad Transition and Employee Assistance Act was unconstitutional. The Court ruled that the challenged provision was a bankruptcy law because it directly affected the distribution of a debtor’s estate and the priorities among creditors. Since the law applied only to one debtor, the Rock Island Railroad, it failed to satisfy the constitutional requirement that Congress establish “uniform Laws on the subject of Bankruptcies throughout the United States.”
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SIEGEL V. FITZGERALD
The Supreme Court held in Siegel v. Fitzgerald 596 U.S. 464 (2022) that the fee disparity violated the Bankruptcy Clause’s requirement of uniformity. The Court concluded that Congress had created a geographically uneven bankruptcy system by imposing significantly different fees on similarly situated debtors depending solely on the district in which they filed.
OFFICE OF THE UNITED STATES TRUSTEE V. JOHN Q. HAMMONS FALL 2006, LLC
The Supreme Court held in Office of the United States Trustee v. John Q. Hammons Fall 2006, LLC 602 U.S. 487 (2024) that prospective parity was the appropriate remedy for the temporary and relatively limited fee disparity identified in Siegel v. Fitzgerald. The Court rejected the debtors’ request for refunds and reversed the Tenth Circuit’s order requiring repayment of the excess fees.
JURISDICTION OF THE BANKRUPTCY COURT
PEPPER V. LITTON
The Supreme Court in Pepper v. Litton 308 U.S. 295 (1939) held that the bankruptcy court had the authority to examine the validity and fairness of a claim and to subordinate or disallow it if equity so required.
CELOTEX CORP. V. EDWARDS
The Supreme Court held in Celotex Corp. v. Edwards514 U.S. 300 (1995) that the bankruptcy court had at least a sufficient basis for exercising “related to” jurisdiction over the dispute. Parties subject to a bankruptcy court order must obey that order unless and until it is modified or reversed. Creditors could not collaterally attack the injunction in another court.
MIDLANTIC NATIONAL BANK V. NEW JERSEY DEPARTMENT OF ENVIRONMENT
The Supreme Court in Midlantic National Bank v. New Jersey Department of Environment 474 U.S. 494 (1986) held that a bankruptcy trustee may not abandon property in contravention of state laws or regulations reasonably designed to protect public health and safety from identified hazards. The bankruptcy court could not authorize abandonment without ensuring adequate protection of the public.
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TRAVELERS INDEMNITY CO. V. BAILEY
The Supreme Court in Travelers Indemnity V. Bailey 557 U.S. 137 (2009) held that the bankruptcy court’s orders approving the reorganization plan and issuing the injunction were final and could not be collaterally attacked years later.
U.S. BANK N.A. V. VILLAGE AT LAKERIDGE, LLC
The Supreme Court held in U.S. Bank N.A. v. Village at Lakeridge, LLC 583 U.S. 153 (2018) that the determination of non-statutory insider status is reviewed under the clear error standard, not de novo review.
SOVEREIGN IMMUNITY AND BANKRUPTCY
TENNESSEE STUDENT ASSISTANCE CORP. V. HOOD
The Supreme Court held in Tennessee Student Assistance Corp. v. Hood 541 U.S. 440 (2004) that a bankruptcy proceeding to determine the dischargeability of a debt owed to a state agency is generally an in rem proceeding, not a suit against the State. Therefore, the Eleventh Amendment does not prevent the bankruptcy court from adjudicating the dischargeability of the debt.
CENTRAL VIRGINIA COMMUNITY COLLEGE V. KATZ
The Supreme Court held in Central Virginia Community College v. Katz 546 U.S. 356 (2006) that a bankruptcy trustee may pursue preference-recovery actions against state agencies in bankruptcy court. The States surrendered their sovereign immunity with respect to certain bankruptcy proceedings when they ratified the Constitution.
UNITED STATES V. NORDIC VILLAGE, INC.
The Supreme Court held in United States v. Nordic Village, Inc503 U.S. 30 (1992) that the Bankruptcy Code did not contain a sufficiently clear and unequivocal waiver of sovereign immunity to permit a monetary recovery against the United States. Consequently, the trustee’s action to recover money from the federal government was barred.
LAC DU FLAMBEAU BAND OF LAKE SUPERIOR CHIPPEWA INDIANS V. COUGHLIN
The Supreme Court held in Lac du Flambeau Band of Lake Superior Chippewa Indians v. Coughlin 599 U.S. 382 (2023) that the Bankruptcy Code unequivocally abrogates the sovereign immunity of Indian tribes with respect to the provisions specified in Section 106(a).
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HOFFMAN V. CONNECTICUT DEPARTMENT OF INCOME MAINTENANCE
The Supreme Court held in Hoffman v. Connecticut Department of Income Maintenance 492 U.S. 96 (1989) that §106(c) did not clearly express Congress’s intent to abrogate state sovereign immunity for monetary recovery actions.
PROPERTY OF ESTATE
CHICAGO BOARD OF TRADE V. JOHNSON
The Supreme Court held in Chicago Board of Trade v. Johnson 264 U.S. 1 (1924) that the Board of Trade membership was property that passed to the bankruptcy trustee, but it passed subject to the restrictions and conditions imposed by the rules of the exchange.
SEGAL V. ROCHELLE
The Supreme Court in Segal v. Rochelle 382 U.S. 375 (1966) held that the tax refund claims were property of the bankruptcy estate and therefore belonged to the trustee for the benefit of creditors.
BUTNER V. UNITED STATES
The Supreme Court held in Butner v. United States440 U.S. 48 (1979) that property interests in bankruptcy are ordinarily created and defined by state law, and unless a federal bankruptcy interest requires a different result, state law should determine the existence and scope of those interests.
UNITED STATES V. WHITING POOLS, INC
The Supreme Court in United States v. Whiting Pools, Inc. 462 U.S. 198 (1983) held that property seized by the IRS before bankruptcy, but not yet sold, remains property of the bankruptcy estate and must be turned over to the debtor under the Bankruptcy Code.
AUTOMATIC STAY
CONTINENTAL ILLINOIS NATIONAL BANK & TRUST CO. V. CHICAGO, ROCK ISLAND & PACIFIC RAILWAY CO.
The Supreme Court in Continental Illinois National Bank & Trust Co. v. Chicago, Rock Island & Pacific Railway Co. 294 U.S. 648 (1935) upheld the bankruptcy court’s authority to stay creditor actions during the reorganization proceeding.
CITIZENS BANK OF MARYLAND V. STRUMPF
The Supreme Court unanimously in Citizens Bank of Maryland v. Strumpf 516 U.S. 16 (1995) held that a temporary administrative hold on a debtor’s bank account, imposed while the bank seeks relief from the automatic stay to exercise a right of setoff, does not violate the automatic stay.
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TAGGART V. LORENZEN
The Supreme Court unanimously in Taggart v. Lorenzen 587 U.S. 161 (2019) held that a court may hold a creditor in civil contempt for violating a discharge order when there is no objectively reasonable basis for concluding that the creditor’s conduct might be lawful.
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RITZEN GROUP, INC. V. JACKSON MASONRY, LLC
The Supreme Court held in Ritzen Group, Inc. v. Jackson Masonry, LLC589 U.S. 302 (2020) an order unreservedly granting or denying relief from the automatic stay is a final, immediately appealable order. Consequently, a party seeking review must appeal within the statutory time limit, and failure to do so results in forfeiture of the right to challenge the order.
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CITY OF CHICAGO V. FULTON
The USA Supreme Court in City of Chicago v. Fulton 592 U.S. 154 (2021) unanimously held that mere retention of property seized before the filing of a bankruptcy petition does not violate § 362(a)(3)’s automatic stay.
UNITED SAVINGS ASSOCIATION OF TEXAS V. TIMBERS OF INWOOD FOREST ASSOCIATES, LTD.
The Supreme Court in United Savings Association of Texas v. Timbers of Inwood Forest Associates, Ltd. 484 U.S. 365 (1988) held that an under secured creditor is not entitled to compensation for the lost opportunity to foreclose and reinvest the proceeds of its collateral during the period of the automatic stay.
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TREATMENT OF CLAIM
VANSTON BONDHOLDERS PROTECTIVE COMMITTEE V. GREEN
The Supreme Court in Vanston Bondholders Protective Committee v. Green 329 U.S. 156 (1946) held that the bondholders were not entitled to recover interest on interest accrued during the bankruptcy proceeding.
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READING CO. V. BROWN
The Supreme Court held in Reading Co. v. Brown 391 U.S. 471 (1968) held that damages resulting from the receiver’s negligence while operating the debtor’s business constituted administrative expenses of the bankruptcy estate and were therefore entitled to priority.
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UNITED STATES V. NOLAND
The Supreme Court held in United States v. Noland 517 U.S. 535 (1996) that a bankruptcy court can not equitably subordinate tax penalty claims on a categorical basis merely because they are penalty claims.
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UNITED STATES V. REORGANIZED CF&I FABRICATORS OF UTAH, INC.
The Supreme Court in United States v. Reorganized CF&I Fabricators of Utah, Inc. 518 U.S. 213 (1996) held that the exaction labelled an “excise tax” by Congress was, in substance, a penalty rather than a tax and therefore was not entitled to priority treatment under the Bankruptcy Code.
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TRAVELERS CASUALTY & SURETY CO. OF AMERICA V. PACIFIC GAS & ELECTRIC CO.
The Supreme Court in Travelers Casualty & Surety Co. of America v. Pacific Gas & Electric Co. 549 U.S. 443 (2007) held that the Bankruptcy Code does not contain a general rule disallowing claims for attorneys’ fees authorized by a valid pre-petition contract and enforceable under applicable state law. The Court rejected the Ninth Circuit’s Fobian rule.
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AVOIDANCE ACTIONS
STELLWAGEN V. CLUM
The Supreme Court held in Stellwagen v. Clum 245 U.S. 605 (1918) that the Bankruptcy Act did not supersede or completely pre-empt state laws concerning fraudulent transfers. The trustee could invoke state-law avoidance rights to recover property transferred by the debtor before bankruptcy.
MOORE V. BAY
The Supreme Court in Moore V. Bay 284 U.S. 4 (1931) held that once a transfer is voidable by any unsecured creditor under applicable state law, the bankruptcy trustee may avoid the transfer in its entirety for the benefit of the bankruptcy estate. The trustee’s recovery is not limited to the amount owed to the creditor whose rights provide the basis for avoidance.
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UNION BANK V. WOLAS
The Supreme Court in Union Bank v. Wolas 502 U.S. 151 (1991) held that payments on long-term debt may qualify for the ordinary course of business exception to preference avoidance. The statute contains no distinction between long-term and short-term debt.
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BEGIER V. INTERNAL REVENUE SERVICE
The Supreme Court held in Begier v. Internal Revenue Service 496 U.S. 53 (1990) that trust fund taxes are not part of the debtor’s bankruptcy estate and therefore cannot be recovered as preferential transfers under §547. The payments made to the IRS were valid because they came from funds held in trust for the government.
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BFP V. RESOLUTION TRUST CORP.
The Supreme Court in BFP v. Resolution Trust Corp. 511 U.S. 531 (1994) held that a non-collusive mortgage foreclosure sale conducted in compliance with applicable state law conclusively establishes “reasonably equivalent value” for purposes of § 548. Such a sale cannot be avoided merely because the sale price is less than the property’s fair market value.
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MERIT MANAGEMENT GROUP, LP V. FTI CONSULTING, INC.
The Supreme Court held in Merit Management Group, LP v. FTI Consulting, Inc. 583 U.S. 366 (2018) that courts must examine the specific transfer that the trustee seeks to avoid, not the component transfers through intermediary financial institutions.
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UNITED STATES V. MILLER
The Supreme Court held in United States V. Miller 604 U.S. 518 (2025) the payments were not avoidable preferences to the extent that they satisfied tax obligations for which responsible corporate officers would otherwise have been personally liable.
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BANK OF AMERICA NATIONAL TRUST & SAVINGS ASSOCIATION V. 203 NORTH LASALLE STREET PARTNERSHIP
The Supreme Court in Bank of America National Trust & Savings Association v. 203 North LaSalle Street Partnership 526 U.S. 434 (1999) held that a reorganization plan giving old equity holders an exclusive opportunity to obtain ownership of the reorganized debtor violates the absolute priority rule unless that opportunity is exposed to market competition.
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RADLAX GATEWAY HOTEL, LLC V. AMALGAMATED BANK
The Supreme Court held in RadLAX Gateway Hotel, LLC v. Amalgamated Bank566 U.S. 639 (2012) that Chapter 11 cramdown plan that proposes to sell collateral free and clear of a secured creditor’s lien cannot be confirmed unless the secured creditor is permitted to credit-bid, unless the court finds cause to deny that right under the Bankruptcy Code.
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CZYZEWSKI V. JEVIC HOLDING CORP.
The Supreme Court held in Czyzewski v. Jevic Holding Corp. 580 U.S. 451 (2017) that a bankruptcy court may not approve a structured dismissal that provides for a final distribution of estate assets in violation of the Bankruptcy Code’s priority rules without the consent of the affected creditors.
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MISSION PRODUCT HOLDINGS, INC. V. TEMPNOLOGY, LLC
The Supreme Court held in Mission Product Holdings, Inc. v. Tempnology, LLC587 U.S. 370 (2019) that rejection of an executory contract under Section 365 constitutes a breach of the contract and does not rescind or terminate rights previously granted to the non-debtor party.
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UNITED STATES V. ENERGY RESOURCES CO.
The Supreme Court in United States v. Energy Resources Co. 495 U.S. 545 (1990) held that bankruptcy courts possess the authority to approve a reorganization plan directing the IRS to apply tax payments first to trust-fund tax liabilities if the court determines that such designation is necessary for the success of the debtor’s reorganization.
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HARTFORD UNDERWRITERS INSURANCE CO. V. UNION PLANTERS BANK, N.A.
The Supreme Court held in Hartford Underwriters Insurance Co. v. Union Planters Bank, N.A. 530 U.S. 1 (2000) that only the trustee (or a debtor-in-possession exercising trustee powers) may seek recovery under §506(c).
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HARRINGTON V. PURDUE PHARMA L.P.
The Supreme Court in Harrington v. Purdue Pharma L.P. 603 U.S. 204 (2024) held that the Bankruptcy Code does not authorize non-consensual third-party releases of claims against non-debtors outside the specific situations expressly provided by Congress.
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TRUCK INSURANCE EXCHANGE V. KAISER GYPSUM CO.
The Supreme Court in Truck Insurance Exchange v. Kaiser Gypsum Co. 602 U.S. 268 (2024) held that Truck Insurance Exchange qualified as a party in interest and was entitled to be heard on issues affecting its financial interests under the proposed reorganization plan. The Supreme Court also held that the insurer had a sufficient stake in the bankruptcy proceeding because the plan could directly affect its potential liability.
CASE V. LOS ANGELES LUMBER PRODUCTS CO., LTD.
The Supreme Court in Case v. Los Angeles Lumber Products Co., Ltd. (308 U.S. 106 (1939) held that the plan was not “fair and equitable” and therefore could not be confirmed.
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EXEMPTIONS
OWEN V. OWEN
The Supreme Court held in Owen v. Owen 500 U.S. 305 (1991) that a debtor may avoid a judicial lien under Section 522(f) if the lien impairs an exemption to which the debtor would have been entitled in the absence of the lien. The Court rejected the argument that state-law limitations on exemptions automatically prevent lien avoidance.
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TAYLOR V. FREELAND & KRONZ
The Supreme Court held in Taylor v. Freeland & Kronz 503 U.S. 638 (1992) that if no timely objection is filed, a claimed exemption becomes effective even if the debtor had no lawful basis for claiming the exemption. Consequently, the trustee could not challenge the exemption after the deadline had passed.
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ROUSEY V. JACOWAY
The Supreme Court held in Rousey v. Jacoway, 544 U.S. 320 (2005) that IRAs qualify as exempt retirement funds under §522(d)(10)(E) of the Bankruptcy Code. Therefore, funds held in IRAs are protected from creditors in bankruptcy proceedings.
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SCHWAB V. REILLY
The Supreme Court held in Schwab v. Reilly 560 U.S. 770 (2010) that the trustee was not required to object because the debtor claimed only a specific dollar-value exemption permitted by the Bankruptcy Code, not the entire asset itself. Therefore, any value in the asset exceeding the statutory exemption amount remained property of the bankruptcy estate and could be administered by the trustee.
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LAW V. SIEGEL
The Supreme Court held in Law v. Siegel 571 U.S. 415 (2014) that a bankruptcy court may not surcharge a debtor’s exempt property to pay administrative expenses, even when the debtor has engaged in fraudulent or bad-faith conduct. The surcharge order therefore violated the Bankruptcy Code.
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CLARK V. RAMEKER
The Supreme Court held in Clark v. Rameker 573 U.S. 122 (2014) unanimously held that inherited IRAs are not “retirement funds” under the Bankruptcy Code and therefore are not exempt from creditors in bankruptcy proceedings.
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CONSUMER BANKRUPTCY
TILL V. SCS CREDIT CORP.
The Supreme Court in Till v. SCS Credit Corp. 541 U.S. 465 (2004) held that the appropriate method is the “formula” or “prime-plus” approach, under which courts begin with the national prime rate and then adjust upward to account for the risk of nonpayment.
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MARRAMA V. CITIZENS BANK OF MASSACHUSETTS
The Supreme Court in Marrama v. Citizens Bank of Massachusetts 549 U.S. 365 (2007) held that a debtor who has engaged in bad-faith conduct does not have an absolute right to convert a Chapter 7 case to Chapter 13. The Court affirmed the denial of Marrama’s motion to convert.
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HAMILTON V. LANNING
The Supreme Court in Hamilton v. Lanning 560 U.S. 505 (2010) held that a bankruptcy court may consider changes in a debtor’s income or expenses that are known or virtually certain at the time of plan confirmation. The Court rejected a purely mechanical application of the statutory formula.
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DEWSNUP V. TIMM
The Supreme Court in Dewsnup v. Timm 502 U.S. 410 (1992) held that Section 506(d) does not permit a Chapter 7 debtor to “strip down” a creditor’s lien to the judicially determined value of the collateral. As long as the creditor’s claim is allowed under Section 502 and is secured by a valid lien, the lien remains enforceable for the full amount of the debt.
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BANK OF AMERICA, N.A. V. CAULKETT
The Supreme Court in Bank of America, N.A. v. Caulkett 575 U.S. 790 (2015) held that a Chapter 7 debtor may not void a wholly underwater junior mortgage lien under Section 506(d). Accordingly, the junior liens held by Bank of America survived the bankruptcy proceedings.
BULLARD V. BLUE HILLS BANK
The Supreme Court unanimously in Bullard v. Blue Hills Bank575 U.S. 496 (2015) held that an order denying confirmation of a Chapter 13 plan is not a final order when the debtor remains free to propose another plan. Such an order is generally not immediately appealable as of right.
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RANSOM V. FIA CARD SERVICES, N.A.
The Supreme Court held in Ransom v. FIA Card Services, N.A. 562 U.S. 61 (2011) that a debtor who does not make loan or lease payments on a vehicle may not claim the vehicle-ownership deduction under the Bankruptcy Code’s means test.
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TOIBB V. RADLOFF
The Supreme Court held in Toibb v. Radloff 501 U.S. 157 (1991) held that Chapter 11 relief is available to individuals regardless of whether they are engaged in business activities. A debtor’s eligibility for Chapter 11 depends upon the statutory requirements of the Bankruptcy Code and not upon the existence of a business enterprise.
JOHNSON V. HOME STATE BANK
The Supreme Court in Johnson v. Home State Bank 501 U.S. 78 (1991) held that a mortgage lien surviving a Chapter 7 discharge remains a “claim” within the meaning of the Bankruptcy Code and may therefore be included in a Chapter 13 repayment plan.
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HARRIS V. VIEGELAHN
The Supreme Court held in Harris v. Viegelahn 575 U.S. 510 (2015) that when a Chapter 13 case is converted to Chapter 7, any undistributed post-petition wages held by the Chapter 13 trustee must be returned to the debtor. The trustee lacks authority to distribute those funds to creditors after conversion.
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ASSOCIATES COMMERCIAL CORP. V. RASH
The Supreme Court held in Associates Commercial Corp V. Rash that when a debtor elects to retain and use collateral under a Chapter 13 cramdown plan, the collateral must be valued according to its replacement value rather than its foreclosure or liquidation value.
DISCHARGE
LOCAL LOAN CO. V. HUNT
The Supreme Court in Local Loan Co. v. Hunt 292 U.S. 234 (1934) held that the wage assignment could not be enforced after the debtor’s discharge in bankruptcy. The Court further held that the bankruptcy court had authority to protect the effectiveness of its discharge order by restraining actions that sought to undermine it.
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GROGAN VS GARNER
The Supreme Court in Grogan V. Garner 498 U.S. 279 (1991) held that the appropriate standard of proof in dischargeability actions under Section 523(a) is the preponderance of the evidence standard. Accordingly, a creditor need only show that it is more likely than not that the debt falls within one of the statutory exceptions to discharge.
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COHEN V. DE LA CRUZ
The Supreme Court in Cohen Vs. Del La Cruz 523 U.S. 213 (1998) held that once it is established that money or property was obtained through fraud, all liabilities arising from that fraud are excepted from discharge. Accordingly, treble damages, attorney’s fees, costs, and other obligations flowing from the fraudulent conduct are nondischargeable to the same extent as the underlying debt.
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ARCHER V. WARNER
The Supreme Court held in Archer V. Warner 538 U.S. 314 (2003) that a bankruptcy court may look beyond the settlement agreement to determine whether the debt originated from fraud. The Court ruled that a settlement does not automatically transform a fraud-based debt into a dischargeable contractual obligation. Consequently, if the debt arose from money, property, or services obtained through fraud, it may remain nondischargeable despite the settlement.
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BULLOCK V. BANKCHAMPAIGN, N.A.
The Supreme Court held in Bullock v. BankChampaign, N.A. that defalcation under Section 523(a)(4) requires a culpable mental state involving knowledge of, or gross recklessness with respect to, the improper nature of the fiduciary conduct. Mere negligence, innocent mistake, or inadvertent breach of fiduciary duty is insufficient to constitute defalcation for purposes of the bankruptcy discharge exception.
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HUSKY INTERNATIONAL ELECTRONICS, INC. V. RITZ
The Supreme Court held in Husky International Electronics, Inc. v. Ritz 578 U.S. 356 (2016) that actual fraud is not limited to fraudulent misrepresentations. The Court ruled that the term encompasses fraudulent conveyance schemes and other forms of intentional fraud designed to hinder, delay, or defraud creditors, even when no false statement has been made.
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LAMAR, ARCHER & COFRIN LLP V. APPLING
The Supreme Court held in Lamar, Archer & Cofrin LLP v. Appling 584 U.S. 709 (2018) that a statement about a single asset can qualify as a statement respecting the debtor’s financial condition if it has a direct relation to or impact on the debtor’s overall financial status. Because Appling’s statement regarding the tax refund concerned his financial condition and was made orally rather than in writing, the debt did not fall within the applicable exception to discharge and was therefore dischargeable.
BARTENWERFER V. BUCKLEY
The Supreme Court held in Bartenwerfer v. Buckley 598 U.S. 69 (2023) that Section 523(a)(2)(A) bars the discharge of debts obtained by fraud even when the debtor personally committed no fraud, provided that the debtor is legally liable for the fraudulent conduct under applicable non-bankruptcy law.
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KAWAAUHAU V. GEIGER
The Supreme Court held in Kawaauhau v. Geiger, 523 U.S. 57 (1998) unanimously that debts arising from negligent or reckless conduct do not fall within §523(a)(6). Only debts resulting from deliberate or intentional injury are excepted from discharge in bankruptcy.
KELLY V. ROBINSON
The Supreme Court held in Kelly v. Robinson 479 U.S. 36 (1986) that criminal restitution obligations imposed as part of a state criminal sentence are not dischargeable in bankruptcy.
YOUNG V. UNITED STATES
The Supreme Court held in Young v. United States 535 U.S. 43 (2002) that three-year lookback period is equitably tolled during the pendency of a prior bankruptcy proceeding.
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HALL V. UNITED STATES
The Supreme Court held in Hall v. United States 566 U.S. 506 (2012) that the taxes were not incurred by the bankruptcy estate and therefore did not qualify for treatment as administrative expenses under §503(b). Consequently, the tax liabilities could not be discharged under §1222(a)(2)(A).
LABOUR & BANKRUPTCY
NLRB V. BILDISCO & BILDISCO
The Supreme Court held in NLRB v. Bildisco & Bildisco 465 U.S. 513 (1984) that collective bargaining agreement is an executory contract that may be rejected under §365(a) if the bankruptcy court determines that rejection is necessary to the reorganization and that the equities favor rejection. A debtor-in-possession does not commit an unfair labor practice merely by failing to comply with the collective bargaining agreement before the court formally approves rejection.
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HOWARD DELIVERY SERVICE, INC. V. ZURICH AMERICAN INSURANCE CO.
The Supreme Court held in Howard Delivery Service, Inc. v. Zurich American Insurance Co. 547 U.S. 651 (2006) that Claims for unpaid workers’ compensation insurance premiums are not entitled to priority as contributions to an employee benefit plan under §507(a)(5).
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Mukesh Suman is a lawyer and legal author based at Delhi, India. He has extensive experience in insolvency and bankruptcy matters. He also provides legal support services to USA based bankruptcy lawyers. Mukesh can be approached at mukesh_suman@outlook.com or +91 9717864570.