Executive Benefits Insurance Agency v. Arkison | |
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Supreme Court of the United States | |
Decided June 9, 2014 | |
Full case name | Executive Benefits Insurance Agency v. Arkison |
Citations | 573 U.S. 25 (more) |
Holding | |
Under Stern v. Marshall, when a bankruptcy court does not have subject matter jurisdiction over a proceeding, the bankruptcy court may still hear the case and issue proposed findings to be reviewed de novo by a federal district court. | |
Court membership | |
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Case opinion | |
Majority | Thomas, joined by unanimous |
Executive Benefits Insurance Agency v. Arkison, 573 U.S. 25 (2014), was a United States Supreme Court case in which the Court held that, under Stern v. Marshall, when a bankruptcy court does not have subject matter jurisdiction over a proceeding, the bankruptcy court may still hear the case and issue proposed findings to be reviewed de novo by a federal district court.
Significance
Because bankruptcy courts in the United States are organized as Article I tribunals rather than as Article III courts, they are not permitted to exercise the judicial power of the United States. Stern v. Marshall identified so-called "Stern claims" that required exercising the judicial power and were therefore beyond the authority of bankruptcy courts. Stern was very disruptive in the sense that, technically, it was not precisely clear what bankruptcy courts could and could not hear for lack of jurisdiction. This case established that bankruptcy courts could continue to hear their cases as before, so long as the Stern claims were later heard by an Article III court with appropriate jurisdiction.
References
- Executive Benefits Insurance Agency v. Arkison, 573 U.S. 25 (2014).
- "Opinion analysis: Bankruptcy judges, attorneys breathe sigh of relief as Court affirms bankruptcy court authority". SCOTUSblog. 2014-06-10. Retrieved 2024-11-13.
External links
- Text of Executive Benefits Insurance Agency v. Arkison, 573 U.S. 25 (2014) is available from: Cornell Findlaw Justia
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