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Marin, As Receiver Of The American Biscuit Company Of Crookston, v. Augedahl

• 1917 • 247 U.S. 142 • White Court
In the 1917 case Marin, as Receiver of The American Biscuit Company of Crookston, v. Augedahl, the U.S. Supreme Court ruled on a dispute involving bankruptcy and debt repayment. The American Biscuit Company had gone bankrupt and its assets were being managed by a receiver (Marin). A creditor (Augedahl) claimed that he was owed money from before the company's bankruptcy filing date. However, Marin argued that this claim should be dismissed because it wasn't filed within six months after...Open Case
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Chief White Court
Term: 1917
Docket: 227
247 U.S. 142
38 S. Ct. 452
62 L. Ed. 1038
1918 U.S. LEXIS 1965

Marin, As Receiver Of The American Biscuit Company Of Crookston, v. Augedahl

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Opinion Summary
AI Abstract

In the 1917 case Marin, as Receiver of The American Biscuit Company of Crookston, v. Augedahl, the U.S. Supreme Court ruled on a dispute involving bankruptcy and debt repayment. The American Biscuit Company had gone bankrupt and its assets were being managed by a receiver (Marin). A creditor (Augedahl) claimed that he was owed money from before the company's bankruptcy filing date. However, Marin argued that this claim should be dismissed because it wasn't filed within six months after adjudication as required by Minnesota state law at that time. The Supreme Court sided with Augedahl stating federal laws regarding bankruptcy take precedence over conflicting state laws in such matters; hence his claim could not be barred due to any limitation prescribed under Minnesota law. This ruling reinforced supremacy of federal law in cases where there is conflict between state and federal statutes.

Dissent Summary
AI Abstract

In the dissenting opinion for Marin v. Augedahl, it was argued that the majority's decision to allow a receiver of an insolvent corporation to recover payments made by the corporation prior to insolvency was incorrect. The dissenting justices believed that these payments were not fraudulent conveyances under Minnesota law because they did not deplete the assets of the company at a time when it was insolvent and unable to pay its debts. They also disagreed with applying federal common law in this case, arguing instead for adherence to state laws on fraudulent transfers and corporate insolvency. Furthermore, they contended that allowing receivers such wide powers could discourage creditors from doing business with corporations out of fear their transactions would be undone if insolvency occurred later on.

Opinion written by Justice WVanDevanter
Decided: May 20, 1918
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