Circuit Judge Ambro Scribes the Boundaries Between Rooker-Feldman and Preclusion
A final judgment on an issue in state court doesn’t by itself deprive federal courts of subject matter jurisdiction under the Rooker-Feldman doctrine, the Third Circuit explains.
A Retirement Plan that’s Not ‘Tax-Qualified’ Is Still Excluded from Estate Property
Declining to create a circuit split, Third Circuit Judge Thomas Ambro held that a retirement plan structured according to ERISA is excluded from estate property even if transactions by the trust violated ERISA or IRS Code regulations.
Bankruptcy Courts Always Have Post-Confirmation Jurisdiction for ‘Core’ Matters
The Third Circuit opinion by Thomas Ambro explained that the ‘close nexus’ test does not apply when a post-conformation dispute is ‘core’ or entails enforcing a court order.