Bullard v. Blue Hills Bank, fka Hyde Park Savings (2014)
- Docket
- 14-116
- Decided
- 2014-01-01
Summary
Question: Is an order denying confirmation of a bankruptcy plan appealable? Conclusion: No. Chief Justice John G. Roberts delivered the opinion for the unanimous Court, which held that a bankruptcy court’s order denying confirmation of a proposed repayment plan is not a “final” order for the purposes of immediate appeal. The Court noted that, because bankruptcy cases typically involve many controversies that could stand on their own, an order is appealable if it finally disposes of a concrete dispute within the larger case. Because denial of confirmation of a plan indicates that a plan needs further consideration, it is not a final disposition of a concrete issue, unless it results in dismissal of the case. The Court held that the asymmetry of allowing confirmation to be a final order, but not denial of a confirmation, is acceptable because only confirmation alters the legal relationships between the parties by allowing the bankruptcy proceedings to proceed. Additionally, there are other safeguards in place, such as interlocutory appeals, to ensure the system is not unfair to debtors.