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United States v. Miller (2024)

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Supreme Court of the United States
United States v. Miller
Term: 2024
Important Dates
Argued: December 2, 2024
Decided: March 26, 2025
Outcome
reversed
Vote
8-1
Majority
Chief Justice John Roberts • Clarence Thomas • Samuel Alito • Sonia Sotomayor • Elena Kagan • Brett Kavanaugh • Amy Coney Barrett • Ketanji Brown Jackson
Dissenting
Neil Gorsuch

United States v. Miller is a case that was decided by the Supreme Court of the United States on March 26, 2025, during the court's October 2024-2025 term. The case was argued before the Supreme Court of the United States on December 2, 2024.

In a 8-1 opinion, the court reversed the judgment of the United States Court of Appeals for the Tenth Circuit, holding that 11 Section 106(a) of the Bankruptcy Code waives the government’s sovereign immunity with respect to a Section 544(b) claim but that waiver does not extend to state-law claims within that federal claim. Justice Ketanji Brown Jackson delivered the opinion of the court.[1]

HIGHLIGHTS
  • The issue: The case concerned the sovereign immunity waiver—11 U.S. Code § 106—of U.S. bankruptcy law. Click here to learn more about the case's background.
  • The questions presented: "Whether a bankruptcy trustee may avoid a debtor's tax payment to the United States under Section 544(b) when no actual creditor could have obtained relief under the applicable state fraudulent-transfer law outside of bankruptcy."[2]
  • The outcome: In a 8-1 opinion, the court reversed the judgment of the United States Court of Appeals for the Tenth Circuit.[1]


    • The case came on a writ of certiorari to the United States Court of Appeals for the Tenth Circuit. To review the lower court's opinion, click here.

    Background

    Case summary

    The following are the parties to this case:[3]

    • Petitioner: United States
    • Respondent: David L. Miller
      • Legal counsel: Lisa S. Blatt (Williams & Connolly LLP)

    The following summary of the case was published by SCOTUSblog:[5]

    “

    In United States v. Miller, the justices agreed to decide a complicated bankruptcy question that arose after All Resort Group, a Utah transportation firm, filed for bankruptcy in 2017. The bankruptcy trustee attempted to reverse a 2014 payment that the company had made of approximately $145,000 to the Internal Revenue Service to cover the personal tax debts of two company officials. It relied on state law that allows four years to recover fraudulent transfers.

    Federal bankruptcy law allows bankruptcy trustees to reverse transfers that a bankruptcy debtor made before filing for bankruptcy if they would be invalid “under applicable law” outside bankruptcy by one of the debtor’s actual creditors. In ARG’s case, the trustee pointed to a debt owed to a former employee, who had sued the company for discrimination and won. But the federal government contended that sovereign immunity would have barred the former employee from suing it to recover the tax payments that ALG had made to the IRS. The question that the justices agreed to take up on Monday is whether a bankruptcy trustee can reverse a debtor’s tax payment to the United States when no actual creditor could have obtained relief.[6]

    		”

    To learn more about this case, see the following:

    Timeline

    The following timeline details key events in this case:


    Questions presented

    The petitioner presented the following questions to the court:[2]

    Questions presented:
    “ Whether a bankruptcy trustee may avoid a debtor's tax payment to the United States under Section 544(b) when no actual creditor could have obtained relief under the applicable state fraudulent-transfer law outside of bankruptcy.[6] ”

    Oral argument

    Audio

    Audio of oral argument:[7]




    Transcript

    Transcript of oral argument:[8]

    Outcome

    In a 8-1 opinion, the court reversed the judgment of the United States Court of Appeals for the Tenth Circuit, holding that 11 Section 106(a) of the Bankruptcy Code waives the government’s sovereign immunity with respect to a Section 544(b) claim but that waiver does not extend to state-law claims within that federal claim. Justice Ketanji Brown Jackson delivered the opinion of the court.[1]

    Opinion

    In the court's majority opinion, Justice Ketanji Brown Jackson wrote:[1]

    “

    In this dispute, a trustee invoked Utah law as the basis for a §544(b) suit seeking to claw back a debtor’s federal tax payment. Ordinarily, the Federal Government’s sovereign immunity would bar any suit against it under Utah law. But the Bankruptcy Code contains a sovereign-immunity waiver, §106(a), that abrogates the Government’s sovereign immunity “with respect to” §544. §106(a)(1). This case requires us to determine the scope of that waiver.

    Specifically, we must decide whether §106(a) abrogates sovereign immunity only with respect to the federal cause of action created by §544(b) or whether it also abrogates sovereign immunity with respect to the underlying state-law claims that supply the “applicable law” for that federal cause of action. We hold that §106(a)’s sovereign-immunity waiver applies only to the §544(b) claim itself and not to any state-law claims nested within that federal claim. Section 106(a) is properly understood as a jurisdictional provision that empowers courts to hear §544(b) claims against the Government to the extent such claims are otherwise available under state law; it does not alter the substantive meaning of §544(b)’s “applicable law” clause. We therefore reverse the decision below. [6]

    		”
    —Justice Ketanji Brown Jackson

    Dissenting opinion

    Justice Neil Gorsuch filed a dissenting opinion.

    In his dissent, Justice Gorsuch wrote:[1]

    “

    The Court has often warned against “‘confus[ing] the doctrine of sovereign immunity with the requirement that a plaintiff state a cause of action.’” Pennhurst State School and Hospital v. Halderman, 465 U. S. 89, 112 (1984) (quoting Larson v. Domestic and Foreign Commerce Corp., 337 U. S. 682, 692–693 (1949)). Yet, to my eyes, the Court’s decision today “suffers a like confusion.” 465 U. S., at 112.

    Three statutory provisions are relevant here. First is 11 U. S. C. §106(a)(1), which waives the government’s sovereign immunity “with respect to” §544 of the Bankruptcy Code. Second is §544(b)(1), which empowers a bankruptcy trustee to invoke the rights of “a creditor holding an unsecured claim” to set aside any transfer “that is voidable under applicable law.” And third is Utah’s fraudulent-transfer statute, which here supplies the “applicable law” for purposes of §544(b)(1). Utah Code §25–6–203(1) (2025).*

    As I see it, those three provisions play out this way. Under the Utah statute, a transfer is “voidable” if, after a creditor’s claim arose against the debtor, the debtor (1) “made the transfer” (2) “without receiving a reasonably equivalent value in exchange,” and (3) “was insolvent at the time.” Notably, no one before us disputes that these conditions are satisfied here and a good fraudulent-transfer claim exists. 71 F. 4th 1247, 1251 (CA10 2023). Thus, under “applicable law,” the relevant transfers are “voidable,” and the bankruptcy trustee can use §544(b)(1) to set them aside. That remains true even though the trustee must sue the United States to void the relevant transfers, because §106(a)(1) bars the government from raising a sovereign-immunity defense in the trustee’s action. [6]

    		”
    —Justice Neil Gorsuch

    Text of the opinion

    Read the full opinion here.

    October term 2024-2025

    See also: Supreme Court cases, October term 2024-2025

    The Supreme Court began hearing cases for the term on October 7, 2024. The court's yearly term begins on the first Monday in October and lasts until the first Monday in October the following year. The court generally releases the majority of its decisions in mid-June.[9]


    See also

    External links

    Footnotes

    1. ↑ 1.0 1.1 1.2 1.3 1.4 U.S. Supreme Court, "United States v. Miller," March 26, 2025
    2. ↑ 2.0 2.1 Supreme Court of the United States, "23-824 UNITED STATES V. MILLER QUESTIONS PRESENTED", June 24, 2024
    3. ↑ Supreme Court of the United States, "No. 23-824," accessed August 13, 2024
    4. ↑ Note: At the time that the Court heard this case's argument, legal counsel was provided by then-U.S. Solicitor General Elizabeth B. Prelogar. Prelogar stepped down from her position on January 20, 2025, following the swearing-in of President Donald Trump (R) to his second term. After taking office, Trump appointed Sarah M. Harris to serve as the acting U.S. Solicitor General until her successor is confirmed and sworn in.
    5. ↑ SCOTUSblog, ""United States v. Miller,"" accessed August 13, 2024
    6. ↑ 6.0 6.1 6.2 6.3 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, "Oral Argument - Audio," argued December 2, 2024
    8. ↑ Supreme Court of the United States, "Oral Argument - Transcript," argued December 2, 2024
    9. ↑ SupremeCourt.gov, "The Supreme Court at Work: The Term and Caseload," accessed January 24, 2022
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