Roee Kiviti, et ux. v. Naveen Prasad Bhatt

Petitioners Roee Kiviti and Adiel Kiviti filed a twocount complaint against Respondent Naveen Bhatt, in connection with Respondent’s bankruptcy, to (i) fix and liquidate Respondent’s debt to Petitioners; and (ii) determine that debt to be nondischargeable. When the nondischargeability count was dismissed, the parties stipulated to dismiss the monetary claim, which had become moot on account of Respondent receiving a discharge. Under Fourth Circuit precedent, the voluntary dismissal of a “doomed” cause of action acts as the entry of a final order for purposes of facilitating appellate review. Affinity Living Grp., LLC v. StarStone Specialty Ins. Co., 959 F.3d 634, 638 (4th Cir. 2020). On appeal, the Fourth Circuit held Petitioners’ damages claim was not “doomed” because the doctrine of mootness does not apply to bankruptcy courts, since bankruptcy courts are not Article III courts and, as such, are not bound by the case-or-controversy requirement of Article III of the Constitution. The question presented is: Whether bankruptcy courts are bound by the caseor-controversy requirement of Article III of the Constitution.