Supreme Court Report

Supreme Court of the United States · Official docket →

Clean Air Car Service & Parking Branch Three, LLC v. Clean Air Car Service & Parking Branch Two, LLC, et al.

Paid petition · United States Court of Appeals for the Second Circuit, No. 24-1742, 24-1738, 24-1743 · judgment May 15, 2025


Certiorari denied · January 12, 2026
Pre-decision estimate: 1% cert probability

Before the decision, well below the 4.1% base rate, with no standout signals pointing toward a grant.

Question presented

There are two issues presented for review:

  1. whether the Bankruptcy Court has subject matter jurisdiction over a bankruptcy petition under 28 U.S.C. § 157 and 28 U.S.C. § 1334, filed by an allegedly managing member on behalf of a bankruptcy debtor, while the petitioners raised an independent claim under the Rooker-Feldman doctrine and 28 U.S.C. § 1738 that the alleged managing member is a bad-faith transferee under U.C.C. § 9-617 and its Official Comments in a U.C.C. Article 9 sale; and

  2. if so, whether the independent claim disputing the ownership of the bankruptcy debtor constitutes an adverse claim sufficient to defeat a buyer’ good-faith purchaser status under 11 U.S.C. § 363(m) in a bankruptcy sale for the bankruptcy debtor’s property.

Counsel of record

For petitioner
Joe Zhenghong Zhou
Law Offices of Joe Zhenghong Zhou & Associates

For respondent
Jay Samuel Hellman

Case

Conference history
Distributed for 1 conference

Proceedings

  1. Jan 12 2026
    Petition DENIED.
  2. Dec 03 2025
    DISTRIBUTED for Conference of 1/9/2026.
  3. Nov 30 2025
    Reply of petitioner Clean Air Car Service & Parking Branch Three, LLC filed. (Distributed)
  4. Nov 17 2025
    Brief of respondents Clean Air Car Service & Parking Branch Two, LLC, et al. in opposition filed.
  5. Sep 19 2025
    Petition for a writ of certiorari filed. (Response due November 17, 2025)