United States v. Miller
View Official PDFBelow are plain-language sections to help you understand what the Court decided in United States v. Miller and why it matters. Quotes are taken from the syllabus (the Court’s short summary at the start of the opinion).
Summary
A short, plain-English overview of United States v. Miller.
In United States v. Miller, the Supreme Court addressed the scope of sovereign immunity waivers under the Bankruptcy Code, specifically § 106(a) and § 544(b). The case involved a bankruptcy trustee seeking to recover funds misappropriated by shareholders of a failed business to pay personal tax liabilities. The Court examined whether § 106(a)'s waiver of sovereign immunity extended to state-law claims incorporated into § 544(b) claims. The Court concluded that the waiver applies only to the federal claim itself, not to the state-law claims embedded within it.
Holding
The single most important “bottom line” of what the Court decided in United States v. Miller.
The Court held that § 106(a)'s waiver of sovereign immunity applies only to a § 544(b) claim itself and not to state-law claims nested within that federal claim.
Constitutional Concepts
These are the Constitution-related themes that appear in United States v. Miller. Click a concept to see other cases that involve the same idea.
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Why Federalism is relevant to United States v. Miller
The case involves the interplay between federal bankruptcy law and state fraudulent-transfer statutes, highlighting the division of power between federal and state governments.
Syllabus excerpt (verbatim)Respondent invoked Utah's fraudulent-transfer statute—which gives creditors a cause of action to invalidate certain transfers by a debtor—as the 'applicable law' underlying his § 544(b) claim.
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Why Separation of Powers is relevant to United States v. Miller
The case discusses the limits of judicial power in the context of sovereign immunity, which is a fundamental aspect of the separation of powers.
Syllabus excerpt (verbatim)Sovereign immunity is jurisdictional in nature and operates to deprive courts of the power to hear suits against the United States absent Congress's express consent.
Key Quotes
Short excerpts from the syllabus in United States v. Miller that support the summary and concepts above.
Section 106(a)'s sovereign-immunity waiver applies only to a § 544(b) claim itself and not to state-law claims nested within that federal claim.
Waivers of sovereign immunity function simply as 'prerequisite[s] for jurisdiction'—they do not create any new substantive rights or alter any pre-existing ones.
The Court's precedents require construing sovereign-immunity waivers narrowly, with any ambiguities resolved in favor of the sovereign.