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18-938 RITZEN GROUP, INC. V. JACKSON MASONRY, LLC, DECISION BELOW: 906 F.3d 494 CERT. GRANTED 5/20/2019 QUESTION PRESENTED: Whether an order denying a motion for relief from the automatic stay is a final order under 28 U.S.C. § 158(a) (1). In diverting from this Court's prior precedent, and in conflict with the First and Third Circuit Courts of Appeal, the Sixth Circuit ruled that an order denying relief from the automatic stay is per se final. LOWER COURT CASE NUMBER: 18-5157, 18-5161
The U.S. Supreme Court case Ritzen Group Inc. v. Jackson Masonry, LLC in 2019 revolved around the issue of bankruptcy proceedings and their impact on litigation between two parties. The dispute began when Ritzen Group sued Jackson Masonry over a breached contract regarding a property sale, but during this process, Jackson filed for bankruptcy which halted the lawsuit under federal law's automatic stay provision for bankrupt entities. When Ritzen sought relief from this stay to continue its lawsuit and was denied by the Bankruptcy Court, it did not immediately appeal this decision but waited until after the conclusion of the entire bankruptcy case to do so. The central question before the Supreme Court was whether an order denying relief from an automatic stay constitutes a final judgment that must be appealed immediately or if it can be appealed at any time during ongoing proceedings as argued by Ritzen Group. In unanimous decision written by Justice Ginsburg, SCOTUS ruled against Ritzen stating that orders resolving motions for relief from an automatic stay are indeed final decisions subject to immediate appeal rather than waiting till end of whole proceeding.
In the dissenting opinion for Ritzen Group Inc. v. Jackson Masonry, LLC, Justice Sotomayor argued that a bankruptcy court's order denying relief from the automatic stay should not be considered a final, immediately appealable order under 28 U.S.C §158(a). Instead, she contended that such an order is merely one step in the broader process of adjudicating whether a creditor has a valid claim against the debtor or its estate. She expressed concern that treating orders denying relief from stay as final could lead to piecemeal appeals and disrupt efficient bankruptcy proceedings by allowing creditors to repeatedly halt these proceedings with interlocutory appeals. Furthermore, she noted this interpretation may disadvantage smaller creditors who lack resources to engage in protracted litigation over interim orders.