Thomson Reuters News & Insight
Featured Content from WESTLAW

Legal

  •  
  •  

File photo of the Supreme Court. REUTERS Larry Downing

U.S. top court looks for meaning in obscure bankruptcy term

3/19/2013 COMMENTS (0)

By Lawrence Hurley

WASHINGTON (Reuters) - For the first time since the bankruptcy code's introduction in 1841 the U.S. Supreme Court will decide the meaning of the word "defalcation," which can refer to embezzlement but also, more generally, to misuse of funds.

The court is considering whether Randy Bullock, an Illinois man who is filing for bankruptcy, can write off money he owes for his role overseeing his father's life insurance trust. Bullock used money from the trust to make investments for himself and other family members. He eventually paid the money back with interest.

The case reached the high court over the question of whether Bullock's actions, which did not deprive the trust of any money, fitted within the legal definition of defalcation, which would mean that, under federal bankruptcy law, he would be barred from seeking bankruptcy relief.

Based on oral arguments on Monday, the justices appeared to be leaning toward finding that defalcation could be used to describe Bullock's actions.

Several justices indicated that they did not think that Bullock's failure to realize that what he was doing was wrong let him off the hook.

"It looks as if you don't need to know that what you're doing is against the law, where you commit defalcation," said Justice Stephen Breyer.

Justice Sonia Sotomayor had a similar reaction.

"If you're a fiduciary, why should an excuse of ignorance of the law ever save you when you are required to exercise the highest protection of the trust?" she said.

That view echoes the position taken by the Obama administration, which intervened in support of the trust, saying in court papers that the law does not require "intentional wrongdoing" for a debtor to be barred from discharging a debt.

'LIKE A BANK ROBBER'

The precise meaning of defalcation has never been determined by the Supreme Court, despite it being part of the bankruptcy code since 1841. Thomas Byrne, Bullock's lawyer, told the justices, "there is no plain contemporary, ordinary meaning that we can resort to with respect to interpretation of the word because it is not in common use."

The justices also delved into the question of whether the fact that there was no overall loss of funds made any difference.

Chief Justice John Roberts pointed out that whether or not there was a loss depends on which day the account balance was checked.

"It's like a bank robber giving back the money," he said. "There is no loss to the bank, but it's still a crime."

Bullock was the sole trustee of his father's life insurance trust from 1978 to 1998.

The trust's only asset was the life insurance policy, which featured a $1 million benefit upon Bullock's father's death. Bullock and his four siblings were the beneficiaries. On three occasions during that period, he used the trust funds to issue loans, two of which he benefited from financially.

Although he paid back the money with interest, his two brothers sued him for breaching his duty as the trustee. A state court ordered him to pay the trust $250,000 plus $35,000 in attorney's fees and other costs.

Bullock, now seeking bankruptcy relief, unsuccessfully asked a federal bankruptcy court in Alabama to discharge the debt to the trust, which is now overseen by BankChampaign.

The Atlanta-based 11th U.S. Circuit Court of Appeals upheld the lower court rulings in favor of the trust.

The case is Bullock v. BankChampaign, U.S. Supreme Court, No. 11-1518.

For petitioner: Thomas Byrne of Sutherland Asbill & Brennan.

For respondent: Bill Bensinger of Baker Donelson.

For United States, amicus in support of respondent: Curtis Gannon, Assistant to the Solicitor General, Department of Justice.

Follow us on Twitter @ReutersLegal | Like us on Facebook   


Register or log in to comment.

© 2013 Thomson Reuters