Ritzen Group, Inc. v. Jackson Masonry, LLC

Ritzen Group, Inc. v. Jackson Masonry, LLC, 589 U.S. ___ (2020) was a United States Supreme Court case from the October 2019 term. In a unanimous opinion, the Supreme Court ruled that "when the bankruptcy court unreservedly grants or denies relief", in this case on a motion for relief from an automatic stay, that decision presents a final order that may be appealed. In a 12-page opinion the Court relied upon its own precedent in Bullard v. Blue Hills Bank to affirm the court below.

Ritzen Group, Inc. v. Jackson Masonry, LLC
Argued November 13, 2019
Decided January 14, 2020
Full case nameRitzen Group, Inc. v. Jackson Masonry, LLC
Docket no.18-938
Citations589 U.S. (more)
140 S. Ct. 582; 205 L. Ed. 2d 419
ArgumentOral argument
Opinion announcementOpinion announcement
Case history
Prior
  • Ritzen Grp., Inc. v. Jackson Masonry, LLC, No. 3:17-CV-00806, 2018 WL 558837 (M.D. Tenn. Jan. 25, 2018)
  • Stay granted, 589 B.R. 601 (M.D. Tenn. 2018)
  • Affirmed sub nom. In re Jackson Masonry, LLC, 906 F.3d 494 (6th Cir. 2018)
  • Cert. granted 139 S. Ct. 2614 (2019)
Holding
An unreserved adjudication of a motion of relief from automatic stay by a bankruptcy court yields a final, appealable order
Court membership
Chief Justice
John Roberts
Associate Justices
Clarence Thomas · Ruth Bader Ginsburg
Stephen Breyer · Samuel Alito
Sonia Sotomayor · Elena Kagan
Neil Gorsuch · Brett Kavanaugh
Case opinion
MajorityGinsburg, joined by unanimous
Laws applied
28 U.S.C. § 158(a)(1)

Background

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Ritzen Group, Inc. agreed to buy land in Nashville, Tennessee from Jackson Masonry, LLC but the land sale was never effected. Ritzen sued for breach of contract in state court but, just days before the trial, Jackson filed for bankruptcy which triggered the automatic stay provision for all lawsuits. Ritzen sued in federal court asking that the state court be compelled to hear the case arguing that the bankruptcy was filed in bad faith.

References

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