Langenkamp v. CulpAnnotate this Case
498 U.S. 42 (1990)
U.S. Supreme Court
Langenkamp v. Culp, 498 U.S. 42 (1990)
Langenkamp v. Culp
Decided Nov. 13, 1990
498 U.S. 42
ON PETITION FOR WRIT OF CERTIORARI TO THE UNITED
STATES COURT OF APPEALS FOR THE TENTH CIRCUIT
Respondents held thrift and passbook savings certificates, which were issued by debtor financial institutions and represented debtors' promise to repay moneys respondents had invested. Within the 90-day period before debtors filed Chapter 11 bankruptcy petitions, respondents redeemed some of the certificates. They became debtors' creditors when they filed proofs of claims against the bankruptcy estates. Subsequently, petitioner trustee instituted adversary proceedings to recover, as avoidable preferences, the payments which respondents had received. After a bench trial, the Bankruptcy Court ruled that the payments were avoidable preferences, and the District Court affirmed. The Court of Appeals, relying on Grandfinanciera, S.A. v. Nordberg,492 U. S. 33, and Katchen v. Landy,382 U. S. 323, reversed, ruling that respondents were entitled to a jury trial in the preference action.
Held: Respondents were not entitled to a jury trial. By filing claims against the bankruptcy estate, respondents triggered the process of "allowance and disallowance of claims," thereby subjecting themselves to the Bankruptcy Court's equitable power. Grandfinanciera, 492 U.S. at 492 U. S. 58- 59, and n. 14. Thus, the trustee's preference action became an integral part of the claims-allowance process, which is triable only in equity. As such, there is no Seventh Amendment right to a jury trial. In contrast, a party who does not submit a claim against the estate is entitled to a jury trial as a preference defendant, since the trustee could recover the transfers only by filing what amounts to a legal action. Ibid. Accordingly, "a creditor's right to a jury trial on a bankruptcy trustee's preference claim depends upon whether the creditor has submitted a claim against the estate," id. at 492 U. S. 58, a distinction overlooked by the Court of Appeals.
Certiorari granted; 897 F.2d 1041, reversed and remanded.
This case presents the question whether creditors who submit a claim against a bankruptcy estate and are then sued by
the trustee in bankruptcy to recover allegedly preferential monetary transfers are entitled to jury trial under the Seventh Amendment. This action was brought by petitioner Langenkamp, successor trustee to Republic Trust & Savings Company and Republic Financial Corporation (collectively debtors). Debtors were uninsured, nonbank financial institutions doing business in Oklahoma. Debtors filed Chapter 11 bankruptcy petitions on September 24, 1984. At the time of the bankruptcy filings, respondents held thrift and passbook savings certificates issued by the debtors, which represented the debtors' promise to repay moneys the respondents had invested.
Within the 90-day period immediately preceding debtors' Chapter 11 filing, respondents redeemed some, but not all, of the debtors' certificates which they held. Thus, upon the bankruptcy filing, respondents became creditors of the now-bankrupt corporations. Respondents timely filed proofs of claim against the bankruptcy estates. Approximately one year after the bankruptcy filing, the trustee instituted adversary proceedings under 11 U.S.C. § 547(b) to recover, as avoidable preferences, the payments which respondents had received immediately prior to the September 24 filing. A bench trial was held, and the Bankruptcy Court found that the money received by respondents did in fact constitute avoidable preferences. Republic Trust & Savings Co., CCH Bkrptcy.L.Rep.