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Donald Neal Rake, Et Al. v. William J. Wade, Trustee

• 1992 • 508 U.S. 464 • Rehnquist Court
The case of Donald Neal Rake v. William J. Wade, Trustee in 1992 revolved around the interpretation of a provision in the Bankruptcy Code relating to interest on tax claims. The petitioner, Rake, filed for Chapter 13 bankruptcy and proposed a plan to pay off his debts over time which included unpaid property taxes. However, the respondent (Wade), as trustee overseeing Rake's bankruptcy estate objected because it did not include post-petition interest on these tax claims as required by Section...Open Case
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Chief Rehnquist Court
Term: 1992
Docket: 92-621
508 U.S. 464
113 S. Ct. 2187
124 L. Ed. 2d 424
1993 U.S. LEXIS 3862
Argued: Mar 22, 1993

Donald Neal Rake, Et Al. v. William J. Wade, Trustee

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Opinion Summary
AI Abstract

The case of Donald Neal Rake v. William J. Wade, Trustee in 1992 revolved around the interpretation of a provision in the Bankruptcy Code relating to interest on tax claims. The petitioner, Rake, filed for Chapter 13 bankruptcy and proposed a plan to pay off his debts over time which included unpaid property taxes. However, the respondent (Wade), as trustee overseeing Rake's bankruptcy estate objected because it did not include post-petition interest on these tax claims as required by Section 1322(b)(10) of the Bankruptcy Code. The Supreme Court ruled unanimously against Rake stating that under section 506(b) of the Bankruptcy code, an oversecured creditor is entitled to receive post-petition interest even if this was not explicitly stated in their agreement with debtor prior to filing for bankruptcy. This decision clarified how certain aspects of debt repayment should be handled during Chapter 13 bankruptcies and established precedent regarding payment obligations towards secured creditors.

Dissent Summary
AI Abstract

In the dissenting opinion for Donald Neal Rake, et al. v. William J. Wade, Trustee (1992), Justice Thomas argued that the majority's interpretation of 11 U.S.C §506(b) was incorrect and inconsistent with Congress' intent when it enacted the Bankruptcy Code in 1978. He contended that under a proper reading of this provision, oversecured creditors should be allowed to recover postpetition interest as part of their secured claim even if they are not receiving current cash payments on their claim during bankruptcy proceedings. This view is based on his belief that such an interpretation would better align with Congress’ objective to ensure fair treatment for all creditors and promote economic stability by preventing unnecessary losses to lenders who have already taken significant risks by extending credit to financially distressed borrowers.

Opinion written by Justice CThomas
Decided: Jun 07, 1993
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Argued: Oct 05, 2026
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