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Ritzen Group Inc. v. Jackson Masonry

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Supreme Court of the United States
Ritzen Group Inc. v. Jackson Masonry LLC
Term: 2019
Important Dates
Argument: November 13, 2019
Decided: January 14, 2020
Outcome
Affirmed
Vote
9-0
Majority
Chief Justice John G. Roberts • Clarence Thomas • Ruth Bader Ginsburg • Stephen Breyer • Samuel Alito • Sonia Sotomayor • Elena Kagan • Neil Gorsuch • Brett Kavanaugh


Ritzen Group Inc. v. Jackson Masonry LLC is a case argued before the Supreme Court of the United States on November 13, 2019, during the court's October 2019-2020 term. The case came on a writ of certiorari to the United States Court of Appeals for the 6th Circuit.[1]

On January 14, 2020, the court affirmed the decision of the 6th Circuit, holding that "a bankruptcy court’s order unreservedly denying relief from the automatic stay constitutes a final, immediately appealable order under §158(a)."[2] Click here for more information about the opinion.

HIGHLIGHTS
  • The case: Ritzen Group and Jackson Masonry both claimed the other breached contract after a sale of property fell through. A lawsuit Ritzen filed against Jackson in Tennessee state court was stayed after Jackson filed for bankruptcy. Ritzen filed a motion to lift the stay, which the bankruptcy court denied. Ritzen then filed a claim against Jackson in bankruptcy court. The bankruptcy court found Ritzen, not Jackson, breached the contract. On appeal, the district court affirmed the bankruptcy court's ruling. On appeal again, the 6th Circuit affirmed the judgments of the district court and bankruptcy court.
  • The issue: Whether an order denying a motion for relief from the automatic stay is a final order under 28 U.S.C. § 158(a) (1). In diverting from this Court's prior precedent, and in conflict with the First and Third Circuit Courts of Appeal, the Sixth Circuit ruled that an order denying relief from the automatic stay is per se final.[3]
  • The outcome: In an unanimous opinion, the court affirmed the 6th Circuit's ruling, holding that "a bankruptcy court’s order unreservedly denying relief from the automatic stay constitutes a final, immediately appealable order under §158(a)."[2]


    • You can review the lower court's opinion here.

    Timeline

    The following timeline details key events in this case:

    • January 14, 2020: The U.S. Supreme Court affirmed the 6th Circuit's ruling.
    • November 13, 2019: Oral argument
    • May 20, 2019: The U.S. Supreme Court agreed to hear the case.
    • January 14, 2019: The petitioner, Ritzen Group Inc., filed a petition with the U.S. Supreme Court.
    • October 16, 2018: The 6th Circuit affirmed the judgments of the district court and bankruptcy court.

    Background

    Ritzen Group contracted to buy property from Jackson Masonry. The sale did not go through. Ritzen and Jackson both claimed the other breached contract. Ritzen sued Jackson for breach of contract in Tennessee state court. The lawsuit was stayed after Jackson filed for bankruptcy. Ritzen filed a motion to lift the stay. The bankruptcy court denied the motion.[4]

    Ritzen then filed a claim against Jackson in bankruptcy court. The bankruptcy court found Ritzen, not Jackson, breached the contract. On appeal, the United States District Court for the Middle District of Tennessee rejected Ritzen's arguments. Ritzen appealed again, and the United States Court of Appeals for the 6th Circuit affirmed the judgments of the district court and bankruptcy court.[4]

    Ritzen petitioned the U.S. Supreme Court to consider the case. In its petition, Ritzen said, "In diverting from this Court’s prior precedent, and in conflict with the First and Third Circuit Courts of Appeal, the Sixth Circuit essentially adopted the 'blanket rule' employed by seven other Circuit Courts of Appeal by holding that an order denying relief from the automatic stay is always a final order. ... Guidance from this Court is necessary to ensure that all bankruptcy litigants, regardless of forum, have a firm understanding of how to determine the finality of an order entered by a bankruptcy court."[5]

    Questions presented

    The petitioner presented the following questions to the court:

    Questions presented:
    • Whether an order denying a motion for relief from the automatic stay is a final order under 28 U.S.C. § 158(a) (1). In diverting from this Court's prior precedent, and in conflict with the First and Third Circuit Courts of Appeal, the Sixth Circuit ruled that an order denying relief from the automatic stay is per se final.[3]

    Outcome

    In a 9-0 opinion, the court affirmed the judgment of the 6th Circuit, holding that "a bankruptcy court’s order unreservedly denying relief from the automatic stay constitutes a final, immediately appealable order under §158(a)." Justice Ruth Bader Ginsburg delivered the opinion of the court.[2]

    Opinion

    In her opinion, Justice Ruth Bader Ginsburg wrote that filing a bankruptcy petition functions as an automatic stay of creditors’ debt-collection efforts outside of the bankruptcy case at issue and that immediate appeal may allow creditors to expedite the establishment of their rights outside of the bankruptcy process, impacting the relief awarded and sought in the bankruptcy case as it progresses:[2]

    “ An appeal of right lies from “final judgments, orders, and decrees” entered by bankruptcy courts “in cases and proceedings.” 28 U.S.C. §158(a). Bankruptcy court orders are considered final and immediately appealable if they “dispose of discrete disputes within the larger [bankruptcy] case.” Bullard v. Blue Hills, 575 U. S. 496, 501.[6] ”

    Text of the opinion

    Read the full opinion here.[2]

    Audio

    Audio of oral argument:[7]



    Transcript

    Transcript of oral argument:[8]

    See also

    External links

    Footnotes

    1. ↑ SCOTUSblog, "Ritzen Group Inc. v. Jackson Masonry LLC," accessed June 6, 2019
    2. ↑ 2.0 2.1 2.2 2.3 2.4 Supreme Court of the United States, "Ritzen Group, Inc. v. Jackson Masonry, LLC," decided January 14, 2020
    3. ↑ 3.0 3.1 Supreme Court of the United States, "Questions presented: 18-938 Ritzen Group, Inc. v. Jackson Masonry LLC," accessed June 6, 2019
    4. ↑ 4.0 4.1 United States Court of Appeals for the 6th Circuit, Ritzen Grp., Inc. v. Jackson Masonry LLC, decided October 16, 2018
    5. ↑ Supreme Court of the United States, "On petition for a writ of certiorari to the United States Court of Appeals for the Sixth Circuit," accessed June 6, 2019
    6. ↑ Note: This text is quoted verbatim from the original source. Any inconsistencies are attributable to the original source.
    7. ↑ Supreme Court of the United States, "Ritzen Group Inc. v. Jackson Masonry LLC," argued November 13, 2019
    8. ↑ Supreme Court of the United States, "Ritzen Group Inc. v. Jackson Masonry LLC," argued November 13, 2019
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