United States Supreme Court

In an action brought by the bankruptcy trustee alleging the fraudulent conveyance of assets from the bankruptcy debtor to defendant, judgment in favor of the trustee is affirmed, where: 1) under the Bankruptcy Amendments and Federal Judgeship Act of 1984, federal district courts have original jurisdiction in bankruptcy cases and may refer to bankruptcy judges two statutory categories of proceedings: "core" proceedings, where bankruptcy judge may hear and determine and enter appropriate orders and judgments, subject to the district court’s traditional appellate review, and "non-core" proceedings, where final judgment must be entered by the district court after de novo review of the bankruptcy judge’s proposed findings of fact and conclusions of law, except that the bankruptcy judge may enter final judgment if the parties consent; 2) in Stern v. Marshall, the Court held that Article III prohibits Congress from vesting a bankruptcy court with the authority to finally adjudicate the "core" claim of tortious interference; 2) where a claim otherwise satisfies 28 U. S. C. section 157(c)(1), the bankruptcy court should simply treat the Stern claim as non-core; 3) section 157(c)(1)’s procedures apply to the fraudulent conveyance claims here, and therefore the bankruptcy court would have been permitted to follow that provision's procedures, i.e., to submit proposed findings of fact and conclusions of law to the district court for de novo review; and 4) the district court's de novo review of the bankruptcy court's order and entry of its own valid final judgment cured any potential error in the bankruptcy court's entry of judgment.

Appellate Information

• Decided 06/09/2014
• Published 06/09/2014

Judges

• THOMAS

Court

• United States Supreme Court

Counsel