Midland Funding, LLC v. Johnson’s Empirical Analysis
581 U.S. 224 · 2017
Citation profile
13 federal appellate · 2 district ·
How this case has been cited
Cited by 62 later decisions — most recently October 2022 · most notably Demarais v. Gurstel Chargo, P.A. (2017), Arias v. Gutman, Mintz, Baker & Sonnenfeldt LLP (2017)
13 federal appellate · 2 district ·
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. § 101 (Bankruptcy Abuse Prevention and Consumer Protection Act of 2005) · 11 U.S.C. § 1301 · 11 U.S.C. § 1302 · 11 U.S.C. § 1328 · 11 U.S.C. § 301 · 11 U.S.C. § 502 · 11 U.S.C. § 558 · 11 U.S.C. § 704
Relies on United States v. Kubrick · Bates v. State Bar of Arizona · Board of Regents of Univ. of State of NY v. Tomanio · Johnson v. Home State Bank · Pennsylvania Department of Public Welfare v. Davenport
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.
“Johnson argues that the Code's word "claim" means "enforceable claim." She notes that this Court once referred to a bankruptcy "claim" as "an enforceable obligation." Pennsylvania Dept. of Public Welfare v. Davenport, 495 U.S. 552 , 559, 110 S.Ct. 2126 , 109 L.Ed.2d 588 (1990). And, she concludes, Midland's "proof of claim" was false (or deceptive or misleading) because its "claim" was not enforceable. But we do not find this argument convincing. The word "enforceable" does not appear in the Code's definition of "claim." See 11 U.S.C. § 101 (5). The Court in Davenport likely used the word "enforceable" descriptively, for that case involved an enforceable debt. 495 U.S. at 559 , 110 S.Ct. 2126 . And it is difficult to square Johnson's interpretation with our later statement that "Congress intended ... to adopt the broadest available definition of 'claim.' " Johnson v. Home State Bank, 501 U.S. 78 , 83, 111 S.Ct. 2150 , 115 L.Ed.2d 66 (1991). It is still more difficult to square Johnson's interpretation with other provisions of the Bankruptcy Code. Section 502(b)(1) of the Code, for example, says that, if a "claim" is "unenforceable," it will be disallowed. It does not say that an "unenforceable" claim is not a "claim." Similarly, § 101(5)(A) says that a "claim" is a "right to payment," "whether or not such right is ... fixed, contingent , ... [or] disputed ." If a contingency does not arise, or if a claimant loses a dispute, then the claim is unenforceable. Yet this section ma”
2 later decisions quote this exact passage · from the majority“The [FDCPA] and the [Bankruptcy] Code have different purposes and structural features. The Act seeks to help consumers .... The Bankruptcy Code, by way of contrast, creates and maintains what we have called the delicate balance of a debtor's protections and obligations.”
2 later decisions quote this exact passage · from the majority“filing of a proof of claim [in a bankruptcy proceeding] that on its face indicates that the limitations period has run”
2 later decisions quote this exact passage · from the majority
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.