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Financial Oversight and Management Board for Puerto Rico v. Cooperative de Ahorro y Credito Abraham Rosa, et al.

Paid petition · United States Court of Appeals for the First Circuit, No. 22-1119 · judgment July 18, 2022


Certiorari denied · February 21, 2023
Pre-decision estimate: 41% cert probability (95% interval 29%–54%)

Before the decision, about 10× the 4.1% base rate. The model weighted this up for counsel who has won certiorari before, a First Circuit decision below, and a circuit split argued in the petition.

Question presented

The decision below is the first by a circuit court in history to hold that the Constitution prohibits a category of unsecured claims from being discharged in bankruptcy. Specifically, the First Circuit held that unsecured claims for just compensation that arise under the Fifth Amendment’s Takings Clause before bankruptcy cannot be adjusted in a bankruptcy case, even though claims for money damages arising under other constitutional provisions can. The court believed the Takings Clause mandates a remedy and that unique feature renders the remedy non-dischargeable. The First Circuit acknowledged it was creating a split with the Ninth Circuit, which, when faced with the identical question, held that pre-bankruptcy unsecured claims for just compensation are dischargeable. The First Circuit’s novel ruling frustrates both pillars of the Constitution’s bankruptcy power—fresh starts for debtors and equitable treatment of unsecured claimholders. The Question Presented is: Are pre-bankruptcy unsecured claims for just compensation under the Takings Clause uniquely non-dischargeable, unlike every other type of unsecured claim?

Counsel of record

For petitioner
Martin J. Bienenstock
Proskauer Rose LLP

For respondent
Russell A. Del Toro
Russell A. Del Toro Sosa Law Office

Case

Conference history
Distributed for 1 conference

Proceedings

  1. Feb 21 2023
    Petition DENIED.
  2. Jan 25 2023
    DISTRIBUTED for Conference of 2/17/2023.
  3. Jan 25 2023
    Reply of petitioner Financial Oversight and Management Board for Puerto Rico filed. (Distributed)
  4. Jan 09 2023
    Brief of respondent United States in opposition filed.
  5. Jan 09 2023
    Brief of respondent Suiza Dairy, Corp. in opposition filed.
  6. Jan 09 2023
    Brief of respondents Oscar Adolfo Mandry-Aparicio, et al. in opposition filed.
  7. Dec 13 2022
    Motion to extend the time to file a response is granted and the time is further extended to and including January 9, 2023, for all respondents.
  8. Dec 12 2022
    Motion to extend the time to file a response from December 19, 2022 to January 9, 2023, submitted to The Clerk.
  9. Nov 07 2022
    The motions to extend the time to file responses are granted and the time is extended to and including December 19, 2022, for all respondents.
  10. Nov 04 2022
    Motion of Oscar Adolfo Mandry-Aparicio, et al. to extend the time to file a response from November 18, 2022 to December 19, 2022, submitted to The Clerk.
  11. Nov 03 2022
    Motion of the Solicitor General to extend the time to file a response from November 18, 2022 to December 19, 2022, submitted to The Clerk.
  12. Oct 17 2022
    Petition for a writ of certiorari filed. (Response due November 18, 2022)