Steinberg v. Buczynski’s Empirical Analysis
40 F.3d 890 · 1994
Citation profile
15 federal appellate · 2 district · 7 state decisions
How this case has been cited
Cited by 62 later decisions — most recently December 2020 · most notably Scholes v. Lehmann (1995), Trenwick America Litigation Trust v. Ernst & Young, L.L.P. (2006)
15 federal appellate · 2 district · 7 state decisions
Later decisions citing this case, by decade. The current decade is in progress, and our corpus holds fewer opinions from the most recent years, so the latest bars are undercounted — not a real decline.
Relationships
Applies 11 U.S.C. § 704
Relies on Caplin v. Marine Midland Grace Trust Co. of New York · Bankers Trust Co. v. Rhoades · Koch Refining v. Farmers Union Central Exchange, Inc. · Levit Vn v. Ingersoll Rand Financial Corporation · Mixon v. Anderson
Most-quoted passages
The sentences later courts lift from this opinion, ranked by how many decisions quote each — the parts of the opinion doing the work. These counts are smaller than the citation total above because most of the 62 citing decisions cite the case generally; a passage count includes only decisions quoting that exact language verbatim.
“The point is simply that the trustee is confined to enforcing entitlements of the [debtor]. He has no right to enforce entitlements of a creditor. He represents the unsecured creditors of the [debtor]; and in that sense when he is suing on behalf of the [debtor] he is really suing on behalf of the creditors of the [debtor]. But there is a difference between a creditor’s interests in the claims of the [debtor] against a third party, which are enforced by the trustee, and the creditor’s own direct — not derivative — claim against the third party, which only the creditor ... can enforce.”
6 later decisions quote this exact passage“In this case, the injury is not insolvency stemming from Appellees’ actions. Here, the injury is the Appellees’ evasion of withdrawal liability. Withdrawal liability is not owed to Twin; rather, it is owed to the pension fund. Because the liability is owed only to the fund, the claim is personal to the Appellant. Moreover, absent a general creditors’ interest, a trustee can only collect money that may be owing to the bankrupt entity. Here, there is no general creditors’ interest in the statutorily imposed withdrawal liability owed to the fund. Rather, the action to recover the withdrawal liability has the character of an action for damages flowing from an alleged illegality against the fund. The alleged illegality may have caused other injuries in addition to those caused to the fund, but the direct injury to the fund — the evasion of its statutory entitlement — defines the nature of plaintiffs claim as a personal one....”
2 later decisions quote this exact passage“When a third party has injured not the bankrupt corporation itself but a creditor of that corporation, the trustee in bankruptcy cannot bring suit against the third party. He has no interest in the suit.”
2 later decisions quote this exact passage
How this case has been treated — in progress
Whether each later court followed, distinguished, criticized, or overruled this decision. The treatment classification (task #35) runs highest-cited cases first and lights up here as it reaches this one.