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Hartford Underwriters Insurance Company v. Union Planters Bank, N. A.

• 1999 • 530 U.S. 1 • Rehnquist Court
The U.S. Supreme Court case Hartford Underwriters Insurance Company v. Union Planters Bank, N.A., 1999 revolved around the interpretation of a provision in the Bankruptcy Code (11 U.S.C §506(c)). The petitioner, Hartford Underwriters Insurance Company had filed an administrative expense claim against Reomar Inc., which was undergoing bankruptcy proceedings. However, after Reomar's assets were sold off and proceeds distributed to secured creditors including respondent Union Planters Bank, there...Open Case
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Chief Rehnquist Court
Term: 1999
Docket: 99-409
530 U.S. 1
120 S. Ct. 1942
147 L. Ed. 2d 1
2000 U.S. LEXIS 3624
Argued: Mar 20, 1900

Hartford Underwriters Insurance Company v. Union Planters Bank, N. A.

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Opinion Summary
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The U.S. Supreme Court case Hartford Underwriters Insurance Company v. Union Planters Bank, N.A., 1999 revolved around the interpretation of a provision in the Bankruptcy Code (11 U.S.C §506(c)). The petitioner, Hartford Underwriters Insurance Company had filed an administrative expense claim against Reomar Inc., which was undergoing bankruptcy proceedings. However, after Reomar's assets were sold off and proceeds distributed to secured creditors including respondent Union Planters Bank, there were insufficient funds left for other claims like that of Hartford. Consequently, Hartford sought recovery from Union Planters under Section 506(c) arguing it allowed any "party in interest" to recover expenses incurred preserving or disposing of a debtor's property securing an allowed secured claim from such creditor if not otherwise recovered under bankruptcy estate provisions. However, the Supreme Court ruled against this broad interpretation stating that only trustees could invoke Section 506(c), thus denying insurance companies or similar entities with indirect interests in bankrupt estates recourse through this section. This decision upheld lower court rulings and clarified legislative intent behind said provision thereby setting precedent for future cases involving similar disputes.

Dissent Summary
AI Abstract

In the dissenting opinion for Hartford Underwriters Insurance Company v. Union Planters Bank, N.A., Justice Stevens argued that the majority's interpretation of 11 U.S.C §506(c) was too narrow and failed to consider Congress' intent when drafting the statute. He believed that Congress intended to give a broad range of parties in interest, including administrative expense claimants like insurance companies, standing to seek recovery under this provision. The majority’s decision would limit such claims only to bankruptcy trustees or debtors-in-possession which he saw as an unnecessary restriction not supported by statutory text or legislative history. Furthermore, he noted that allowing more parties to recover under §506(c) could promote efficiency in bankruptcy proceedings by reducing duplicative litigation and encouraging cooperative resolution of claims.

Opinion written by Justice AScalia
Decided: May 30, 1900
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