Siegel v. Fitzgerald | |
---|---|
Argued April 18, 2022 Decided June 6, 2022 | |
Full case name | Alfred H. Siegel, Trustee of the Circuit City Stores, Inc. Liquidating Trust v. John P. Fitzgerald, III, Acting United States Trustee for Region 4 |
Docket no. | 21-441 |
Citations | 596 U.S. ___ ( more ) |
Argument | Oral argument |
Court membership | |
| |
Case opinion | |
Majority | Sotomayor, joined by unanimous |
Laws applied | |
Bankruptcy Judgeship Act of 2017 |
Siegel v. Fitzgerald, 596 U.S. ___ (2022), was a United States Supreme Court case related to the United States bankruptcy courts.
Congress created the United States Trustee Program in the 1980s to transfer administrative functions of the bankruptcy courts to the executive branch. When it did so, Alabama and North Carolina were provided exemptions, remaining under the bankruptcy administrator program instead. Chapter 11 debtors in Trustee Program courts pay quarterly fees throughout the duration of their case, while debtors in administrator states were exempt until 2001, when the Judicial Conference of the United States issued a standing order making the fees the same rates in both systems. In 2017, the Trustee Fund faced a shortfall in funds, so Congress passed the Bankruptcy Judgeship Act of 2017, increasing fees dramatically in Trustee Program districts. The Judicial Conference extended the hike to administrator program districts, but only for new cases. Circuit City filed for bankruptcy in 2008, in a Trustee Program district, and saw its fees dramatically increase due to the hike. It challenged the increase as violating the uniformity requirement of the United States Constitution's Bankruptcy Clause. The bankruptcy court agreed, but the United States Court of Appeals for the Fourth Circuit reversed, over the dissent of Judge A. Marvin Quattlebaum Jr. [1]
Certiorari was granted in the case on January 10, 2022. Oral arguments were held on April 18, 2022. On June 6, 2022, the Supreme Court issued a unanimous opinion reversing the Fourth Circuit as to the constitutionality of the fee increase, while remanding for consideration of what the remedy should be.
The United States courts of appeals are the intermediate appellate courts of the United States federal judiciary. They hear appeals of cases from the United States district courts and some U.S. administrative agencies, and their decisions can be appealed to the Supreme Court of the United States. The courts of appeals are divided into 13 "Circuits". Eleven of the circuits are numbered "First" through "Eleventh" and cover geographic areas of the United States and hear appeals from the U.S. district courts within their borders. The District of Columbia Circuit covers only Washington, DC. The Federal Circuit hears appeals from federal courts across the United States in cases involving certain specialized areas of law.
United States bankruptcy courts are courts created under Article I of the United States Constitution. The current system of bankruptcy courts was created by the United States Congress in 1978, effective April 1, 1984. United States bankruptcy courts function as units of the district courts and have subject-matter jurisdiction over bankruptcy cases. The federal district courts have original and exclusive jurisdiction over all cases arising under the bankruptcy code,, and bankruptcy cases cannot be filed in state court. Each of the 94 federal judicial districts handles bankruptcy matters.
The United States Trustee Program is a component of the United States Department of Justice that is responsible for overseeing the administration of bankruptcy cases and private trustees. The applicable federal law is found at 28 U.S.C. § 586 and 11 U.S.C. § 101, et seq.
In the United States, bankruptcy is largely governed by federal law, commonly referred to as the "Bankruptcy Code" ("Code"). The United States Constitution authorizes Congress to enact "uniform Laws on the subject of Bankruptcies throughout the United States". Congress has exercised this authority several times since 1801, including through adoption of the Bankruptcy Reform Act of 1978, as amended, codified in Title 11 of the United States Code and the Bankruptcy Abuse Prevention and Consumer Protection Act of 2005 (BAPCPA).
Thomas Lee Ambro is a Senior United States circuit judge of the United States Court of Appeals for the Third Circuit.
Travelers Casualty & Surety Co. of America v. Pacific Gas & Elec. Co., 549 U.S. 443 (2007), was a United States Supreme Court case about attorney's fees in bankruptcy cases. Justice Samuel Alito wrote the opinion for a unanimous court.
Toibb v. Radloff, 501 U.S. 157 (1991), was a case in which the United States Supreme Court held that individuals are eligible to file for relief under the reorganization provisions of chapter 11 of the United States Bankruptcy Code, even if they are not engaged in a business. The case overturned the lower courts ruling which restricted individuals to chapter 7.
A Referee in Bankruptcy or Bankruptcy Referee was a federal official with quasi-judicial powers, appointed by a United States district court to administer bankruptcy proceedings, prior to 1979. The office was first created by the Bankruptcy Act of 1898, and was abolished by the Bankruptcy Reform Act of 1978, which created separate United States bankruptcy courts with permanently assigned judges.
Stern v. Marshall, 564 U.S. 462 (2011), was a United States Supreme Court case in which the Court held that a bankruptcy court, as a non-Article III court lacked constitutional authority under Article III of the United States Constitution to enter a final judgment on a state law counterclaim that is not resolved in the process of ruling on a creditor's proof of claim, even though Congress purported to grant such statutory authority under 28 U.S.C. § 157(b)2(C). The case drew an unusual amount of interest because the petitioner was the estate of former Playboy Playmate and celebrity Anna Nicole Smith. Smith died in 2007, before the Court decided the case, which her estate lost.
United States v. More, 7 U.S. 159 (1805), was a United States Supreme Court case in which the Court held that it had no jurisdiction to hear appeals from criminal cases in the circuit courts by writs of error. Relying on the Exceptions Clause, More held that Congress's enumerated grants of appellate jurisdiction to the Court operated as an exercise of Congress's power to eliminate all other forms of appellate jurisdiction.
Connecticut National Bank v. Germain, 503 U.S. 249 (1992), was a case in which the Supreme Court of the United States held that an interlocutory order of a district court, sitting as an appellate court in a bankruptcy case, is in turn reviewable by the court of appeals when authorized under 28 U.S.C. § 1292. Although the Justices were unanimous in deciding the specific statutory interpretation issue concerning bankruptcy appeals that the case presented, they disagreed on the extent to which it was appropriate to refer to the legislative history of the statute in resolving the case.
Things Remembered, Inc. v. Petrarca, 516 U.S. 124 (1995), was a case in which the United States Supreme Court held that when an action has been removed from state court to a United States Bankruptcy Court, and the bankruptcy court remands to state court because of a timely-raised defect in removal procedure or lack of subject-matter jurisdiction, the removal statute precludes a United States Court of Appeals from reviewing the order.
Law v. Siegel, 571 U.S. 415 (2014), is a ruling of the Supreme Court of the United States that describes the extent of the powers of bankruptcy courts in dealing with the bad faith of debtors.
Harris v. Viegelahn, 575 U.S. 498 (2015), was a United States Supreme Court case in which the Court clarified procedures for disposing wages after a debtor files for bankruptcy. In a unanimous opinion written by Justice Ruth Bader Ginsburg, the Court held that if a debtor earns money after filing Chapter 13 bankruptcy proceedings, and converts to Chapter 7 bankruptcy before the money is sent to creditors, the debtor is permitted to keep those funds.
Fisher v. University of Texas, 579 U.S. 365 (2016), also known as Fisher II, is a United States Supreme Court case which held that the Court of Appeals for the Fifth Circuit correctly found that the University of Texas at Austin's undergraduate admissions policy survived strict scrutiny, in accordance with Fisher v. University of Texas (2013), which ruled that strict scrutiny should be applied to determine the constitutionality of the University's race-conscious admissions policy.
Houston Community College System v. Wilson, 595 U.S. ___ (2022), is a United States Supreme Court case involving the First Amendment to the United States Constitution. The unanimous Court held that a local government board member's freedom of speech was not abridged when he was verbally censured by his colleagues.
American Hospital Association v. Becerra, 596 U.S. ___ (2022), was a United States Supreme Court case relating to administrative law. The case centered on a rule from the Department of Health and Human Services, which reduced reimbursement rates for certain hospitals. Several hospital associations and hospitals affected by the rule sued HHS, alleging that it exceeded its statutory authority. The court was tasked with deciding if the rule was a reasonable interpretation of the law, and if the statute blocked judicial review of the rule in the first place.
Southwest Airlines Co. v. Saxon, 596 U.S. ___ (2022), was a United States Supreme Court case related to the scope of the Federal Arbitration Act, in which the Court unanimously held that cargo loaders and ramp supervisors employed at airports are exempt from the Federal Arbitration Act.
Garland v. Gonzalez, 596 U.S. ___ (2022), was a United States Supreme Court case related to immigration detention.
Johnson v. Arteaga-Martinez, 596 U.S. ___ (2022), was a United States Supreme Court case related to immigration detention.