Pennsylvania Eastern District

Public Rights Exception Permits Bankruptcy Court to Award Punitive Damages

Although a suit for punitive damages resembles a claim for which there would be a jury under common law, Pennsylvania’s Judge Mayer decided that the enactment of Section 362(k) gave rise to the public rights exception allowing bankruptcy courts to award damages without a jury.

Dismissal Isn’t Mandatory if a New Filing Is Within 180 Days of a Voluntary Dismissal

Courts are split on whether Section 109(g)(2) mandates dismissal whenever an individual or family farmer refiles within 180 days, regardless of whether a lift-stay motion prompted dismissal of the first case.

‘Earmarking’ Only Applies When a Debtor Receives a Loan from a Third Party

Money taken from a debtor’s own retirement account to pay a creditor does not qualify for the earmarking defense, Chief Judge Fehling says.