Statute Annotations › Federal › 28 U.S.C. § 157

28 U.S.C. § 157

Procedures for bankruptcy cases and proceedings: the cases that interpreted this section

Jurisdiction
Federal
Case notes
6,735
Cited in passing
21,183
Citing cases indexed
45,972
Case dates
1984–2026
Screened through
2026-06-26
Checked for later law changes
2026-10-19
Courts' treatment: partly invalid
A reviewed case holds part of this section invalid or unenforceable.
This reflects what the reviewed cases said, not legislative action: a later amendment or repeal by the legislature would not appear here unless a reviewed case discussed it.

27,918 citing cases reviewed of 45,972 in the citation index: 6,735 interpreted the section (annotated below), 21,183 cited it only in passing. Cases filed after 2026-06-26 may not have been reviewed yet.

Have a situation under 28 U.S.C. § 157?

These notes show how courts have ruled. Ask about your specific facts and see which of these rulings apply, with citations you can check.

Core proceedings involving claims

Section 157(b)(2)(B) treats the allowance or disallowance of a creditor’s proof of claim as a core proceeding, even when the claim arises from a prepetition state-law contract dispute.

S.G. Phillips Constructors, Inc. v. City of Burlington (In re S.G. Phillips Constructors, Inc.) · filed 1995-01-25(b)(2)(B)

Rather, we believe that the determinative factor as to the bankruptcy court’s jurisdiction in this case is that the City filed a proof of claim resulting in an adversary proceeding that involved the “allowance or disallowance of claims against the estate.” 28 U.S.C. § 157(b)(2)(B). In so doing, the City necessarily became a party under the court’s core jurisdiction.
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Section 157(b)(2)(B) gives a bankruptcy court core jurisdiction to hear a motion to file a late claim under a confirmed Chapter 11 plan.

In Re Confidential Investigative Consultants, Inc. · filed 1995-02-10(b)(2)(B)

Thus, this Court has core jurisdiction under 28 U.S.C. § 157(b)(2)(B) to entertain a motion under Pioneer for Jones to file a late claim in order to participate in the Plan.
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Section 157(b)(2)(B) treats proceedings seeking allowance or disallowance of claims against the estate as core proceedings.

Chiang v. Barclays Bank, PLC (In Re Caledonia Springs, Inc.) · filed 1995-08-15(b)(2)(B)

In addition, by attempting to prohibit Barclays from partaking in the bankruptcy proceeding, appellants appear to be seeking disallowance of Barclays’ claim against the estate, and the “allowance or disallowance of a claim” is defined as a core proceeding under 28 U.S.C. § 157(b)(2)(B).
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Section 157(b)(2)(B) treats a debtor’s entitlement to an exemption as a core bankruptcy matter.

Gazes v. DeArakie (In Re DeArakie) · filed 1996-08-22(b)(2)(B)

However, here, no Seventh Amendment rights are implicated and the issue of whether a debtor is entitled to an exemption is plainly a core matter. 28 U.S.C. § 157(b)(2)(B).
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Section 157(b)(2)(B) treats the allowance or disallowance of a filed proof of claim as a core proceeding within the bankruptcy court’s jurisdiction.

Benedor Corp. v. Conejo Enterprises, Inc. (In re Conejo Enterprises, Inc.) · filed 1996-08-23(b)(2)(B)

The allowance' and disallowance of claims against the estate is a core proceeding. 28 U.S.C. § 157(b)(2)(B). Once Bene-dor filed its proof of claim, it subjected its claim to the core jurisdiction of the bankruptcy court.
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Section 157(b)(2)(B) treats a proceeding to determine whether to allow or disallow a claim as a core proceeding.

In Re Stoecker · filed 1996-10-17(b)(2)(B)

This matter constitutes a core proceeding under 28 U.S.C. § 157(b)(2)(B).
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Section 157 permits a bankruptcy court hearing a core creditor claim to determine the claim’s amount together with its dischargeability.

Shannon v. Russell (In Re Russell) · filed 1996-12-18(b)(2)(B)

The Court notes at the outset that it has the requisite authority to award damages in this case. A “suit by a third party creditor ... against the debtor (and thus the bankruptcy estate), is a ‘core proceeding’ under 28 U.S.C. § 157(b)(2)(B).
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Section 157(b)(2)(B) treats proceedings addressing the allowance or disallowance of claims against the estate as core proceedings.

In Re Markos Gurnee Partnership · filed 1997-04-01(b)(2)(B)

The pending proceeding is a core proceeding under 28 U.S.C. § 157(b)(2)(B), since it addresses the allowance or disallowance of claims against the estate.
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Section 157(b)(2)(B) treats the allowance or disallowance of a claim against the bankruptcy estate as a core proceeding.

In Re Nelson · filed 1997-03-31(b)(2)(B)

This matter involves the allowance or dis-allowance of a claim against the bankruptcy estate of Charley Mae Nelson. Pursuant to 28 U.S.C. § 157(b)(2)(B), resolution of this matter is a core proceeding.
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Section 157(b)(2)(B) treats the allowance of claims as a core proceeding in which a bankruptcy court may enter a final order.

In Re Gene · filed 1997-04-17(b)(2)(B)

This is a core proceeding under 28 U.S.C. § 157(b)(2)(B). Accordingly, the bankruptcy court is authorized to enter a final judgment or order subject to those appeal rights afforded by 28 U.S.C. § 158 in accord with Fed.R.Bankr.P. 8001 and 8002.
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Section 157(b)(2)(B) places allowance and disallowance of secured and unsecured claims within the bankruptcy court’s authority.

In Re Psychiatric Hospitals of Florida Inc. · filed 1997-04-28(b)(2)(B)

By virtue of 28 U.S.C. § 157(b)(2)(B), it is uniquely within the competence of the bankruptcy court to allow or disallow claims, secured or unsecured.
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Section 157(b)(2)(B) does not make a damages suit a core proceeding merely because it may establish the amount of a potential claim against the bankruptcy estate.

Bevilacqua v. Bevilacqua · filed 1997-05-08(b)(2)(B)

Plaintiffs damage claim may merely quantify damages for defendant’s having unlawfully occupied plaintiffs premises. It does not involve the “allowance or disallowance of claims against the estate” in the sense that it will determine whether plaintiff has a claim against the estate.
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Section 157 treats malpractice claims against court-appointed professionals arising from their services to the bankruptcy estate as core proceedings.

Pipkin v. Henry & Peters, P.C. (In Re R & C Petroleum, Inc.) · filed 1999-06-07

Pipkin avers that the fee application judgment was not final as to the issue of malpractice because any proceeding to determine malpractice is “non-core” as defined under 28 U.S.C. § 157. This Court must disagree. ... A malpractice claim like the present one [non-disclosure and dereliction of duty by the accountants] inevitably involves the nature of services performed for the debtor’s estate and the fees awarded under superintendence of the bankruptcy court; it cannot stand alone. ... The Fifth Circuit Court’s reasoning in Southmark applies here.
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Section 157 treats a proceeding that is in substance a proof of claim against the debtor as core, even when it also names nondebtors.

Red Bell Brewing Co. v. GS Capital, L.P. (In Re RBGSC Investment Corp.) · filed 1999-11-02(b)

The instant Proceeding asserts claims against the Debtor, as well as against the Nondebtors. It therefore is in substance a proof of claim. ... As such, the instant proceeding is core.
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Section 157(b) does not treat FOIA discovery requests as core proceedings when their outcome cannot affect the bankruptcy estate.

Lucabaugh v. Internal Revenue Service (In Re Lucabaugh) · filed 2000-12-19(b)

Second, appellant’s discovery requests under the FOIA did not constitute a core proceeding because his claims were not related to his bankruptcy case — the outcome of the claims could not have any effect on the estate being administered in bankruptcy.
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Section 157 limits the bankruptcy court’s exclusive jurisdiction to core proceedings.

Grocery Marketing, Inc. v. White Lion Foods, Inc. · filed 2000-12-20(b)

Under federal law the bankruptcy court has exclusive jurisdiction only over “core” proceedings. ... The counterclaim was not a core proceeding.
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Section 157(b)(2)(B) does not make a removed state-law counterclaim against a debtor a core proceeding when no proof of claim against the estate has been filed.

Asousa Partnership v. Pinnacle Foods, Inc. (In Re Asousa Partnership) · filed 2001-07-02(b)(2)(B)

Consequently, the instant adversary proceeding, despite the fact that it includes a counterclaim against the debtor, does not involve the “allowance or disallowance” of claims against the estate. Thus, it is not a core proceeding pursuant to § 157(b)(2)(B).
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Section 157(b)(2)(B) makes a proceeding core when resolving it will determine whether a claim against the bankruptcy estate is allowed.

Cibro Petroleum Products, Inc. v. City of Albany (In Re Winimo Realty Corp.) · filed 2001-10-25(b)(2)(B)

Second, the City’s proof of claim triggered the Bankruptcy Court’s core jurisdiction under section 157(b)(2)(B). The City’s proof of claim seeks payments allegedly due under the PILOT Agreement and the PILOT Proceeding will determine if that Agreement is valid and whether Cibro breached that agreement.
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A proceeding that adjusts the debtor-creditor relationship, including a dispute over a tax refund and setoff, is a core proceeding the bankruptcy court may decide.

In Re: Gordon Sel-Way, Inc., Debtor. Gordon Sel-Way, Inc. v. United States · filed 2001-10-26(b)(2)(O)

As noted above, the adjudication of Sel-Way’s tax refund claim and the government’s right to setoff will determine Sel-Way and the government’s rights vis-a-vis one another. Thus it is clear that the bankruptcy court did have core subject matter jurisdiction over this case.
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Section 157(b)(2) gives bankruptcy courts authority to apply marshaling against tax authorities when it affects claim allowance and liquidation of estate assets.

Ramette v. United States (In Re Bame) · filed 2001-12-21(b)(2)

Applying marshaling to the IRS and MDOR is within the authority of the bankruptcy courts as part of the claim allowance process as well as being a proceeding that affects the liquidation of assets of the estate.
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Section 157 treats a proceeding as core only if it is integral to the bankruptcy court’s basic function and historically entrusted to that court.

Gray v. Executive Risk Indemnity, Inc. (In Re Molten Metal Technology, Inc.) · filed 2002-01-03(b)

Accordingly, under the guiding precedent in this Circuit, a proceeding is “core” under § 157(b) only if it is integral to the basic function of the bankruptcy court and historically has been entrusted to the bankruptcy court, not reserved exclusively for Article III courts.
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Section 157(b) treats demands for relief from the automatic stay and plan injunctions as core proceedings.

Executive Risk Indemnity, Inc. v. Boston Regional Medical Center, Inc. (In Re Boston Regional Medical Center, Inc.) · filed 2002-04-02(b)

These demands — for a determination that the stay and injunctions do not enjoin payment of defense costs, and, in the alternative, for relief from the stay and injunctions to permit payment of such costs — clearly arise under the Bankruptcy Code, the confirmed plan, and the confirmation order, and are central to the bankruptcy process. They are core proceedings.
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Section 157(b)(2)(B) treats allowance and disallowance of claims as core proceedings, but the court must examine the nature of the particular claim.

Pittsburgh Corning Corp. v. Mingo (In re Pittsburgh Corning Corp.) · filed 2002-05-06(b)(2)(B)

Although § 157(b)(2)(B) of title 28 provides that matters involving the allowance and disallowance of claims are core proceedings, the particular claim at issue must fall within one of the specific categories of core proceedings listed in § 157(b)(2)(B).
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Section 157(b)(2)(B) treats an objection to a claim as a core proceeding even when the claim is based in part on the FDCPA.

In Re Creditrust Corp. · filed 2002-06-17(b)(2)(B)

This Court has subject matter jurisdiction over this dispute which is a core matter because it involves an objection to a claim, 28 U.S.C. § 157(b)(2)(B), albeit a claim based in part upon the FDCPA.
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Section 157(b) permits a bankruptcy court to consider an untimely objection to discharge as a core proceeding.

Kontrick, Andrew J. v. Ryan, Robert A. · filed 2002-07-08(b)

Thus, there is nothing within § 157(b) to indicate that a bankruptcy court is precluded from considering untimely objections to discharge.
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Section 157(b)(2)(B) treats allowance or disallowance of claims against the estate as core proceedings, permitting the bankruptcy court to enter final orders.

In re Gillis · filed 2002-10-31(b)(2)(B)

As the allowance or disallowance of claims against the estate are core proceedings pursuant to 28 U.S.C. § 157(b)(2)(B), this Court has been conferred with the jurisdictional authority to enter final orders in this matter.
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Section 157(b)(2)(B) treats exemption disputes as core proceedings that the bankruptcy court may finally decide.

In Re Hughes · filed 2003-02-12(b)(2)(B)

Thus, by virtue of 28 U.S.C. § 1334(d) and by virtue of 28 U.S.C. § 157(b)(2)(B), this Court has the power to make a final binding determination concerning a dispute which involves a challenge of a claim of exemption asserted by the Debtor.
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Section 157(b)(2)(B) treats allowance or disallowance of claims against the estate as a core proceeding.

In Re Goldberg · filed 2003-01-27(b)(2)(B)

This matter is a core proceeding under 28 U.S.C. § 157(b)(2)(B) and the court has jurisdiction under 28 U.S.C. § 1334.
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Section 157(b) does not treat a dispute over a payment agreement as a core proceeding when the bankruptcy court’s sale order merely ratified that agreement; the resulting claim is for breach of contract.

Concerto Software, Inc. v. Vitaquest International, Inc. · filed 2003-03-04(b)

Thereafter, any dispute under the agreement is simply an action for breach of contract. ... An action for breach of contract does not “arise in” or “arise under” title 11.
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Section 157 treats proceedings involving claims against the estate, estate counterclaims, and the avoidance and recovery of fraudulent conveyances as core proceedings.

Word Investments, Inc. v. Bruinsma (In Re TML, Inc.) · filed 2003-03-26(b)(2)(B), (C), and (H)

This adversary proceeding is a core proceeding because it involves the allowance or disallowance of claims against the estate, counterclaims by the estate, and seeks an avoidance and recovery of fraudulent conveyances.
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Section 157(b)(2) treats recognition of a garnishment judgment against an estate creditor as a core proceeding when it concerns estate administration and determines who receives a distribution.

In Re Brickell · filed 2003-04-10(b)(2)

Core proceedings include but are not limited to matters concerning the administration of the bankruptcy estate, the allowance or disallowance of claims against the estate, and other proceedings affecting the adjustment of the debtor-creditor relationship. 28 U.S.C. § 157(b)(2)(A), (B), and (O). A request by the holder of a garnishment judgment against a creditor of a bankruptcy estate for this Court to recognize such garnishment is a matter concerning the administration of the bankruptcy estate, is integrally related to a claim against the estate, and affects the adjustment of the debtor-creditor relationship by determining the holder of the claim entitled to distribution.
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Section 157(b)(2)(B) makes proceedings to allow or disallow claims against a debtor core proceedings, even when state law governs the claim.

HQ Global Workplaces, Inc. v. Bank of Nova Scotia (In Re HQ Global Holdings, Inc.) · filed 2003-06-10(b)(2)(B)

Proceedings to allow or disallow claims against a debtor are expressly core. 28 U.S.C. § 157(b)(2)(B). The Bankruptcy Court is not deprived of its core jurisdiction over a claim simply because that claim must be decided under state law.
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An interpleader involving a bankruptcy trustee’s claim to a possible estate asset is a core proceeding under § 157(b).

Kepley Broscious, PLC v. Ahearn (In Re Ahearn) · filed 2003-09-30(b)

Because the instant interpleader action involves a claim by the bankruptcy trustee to a possible asset of the estate, the court treats the action as a core proceeding as defined in 28 U.S.C. § 157(b).
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Section 157(b)(2)(B) treats allowance or disallowance of claims against a debtor as a core proceeding.

Cytomedix, Inc. v. Bennett · filed 2003-09-30(b)(2)(B)

As allowance or disallowance of claims against a debtor are “core proceedings” under 28 U.S.C. § 157(b)(2)(B), and the transfer of counts I-IV obviates the need for withdrawal under 28 U.S.C. § 157(d), I refer these counts back to the bankruptcy court for resolution.
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Section 157(b) determines core status for an entire adversary proceeding, including related third-party claims, rather than separately for each claim.

Pierce v. Conseco Finance Servicing Corp. (In Re Lockridge) · filed 2003-12-15(b)

This is because under § 157(b) the core determination is made with respect to the entire proceeding, not with respect to each particular claim made within a proceeding.
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Section 157(b)(2)(A) does not make a debtor’s prepetition state-law contract claim a core proceeding merely because recovery would benefit the bankruptcy estate.

Porter-Hayden Co. v. First State Management Group, Inc. (In Re Porter-Hayden Co.) · filed 2004-01-12(b)(2)(A)

However, treating this contract dispute as a “core proceeding” would create an exception to Marathon that would “swallow the rule,” as any contract action that the Plaintiff would pursue against a defendant would likely be expected to inure to the benefit of the estate and thus “concern” its “administration.”
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Section 157(b) does not treat a debtor’s prepetition contract collection suit as a core proceeding when the suit is only related to the bankruptcy case.

Durango Georgia Converting, LLC v. TST Impreso, Inc. (In Re Durango Georgia Paper Co.) · filed 2004-01-22(b)

Based on Durango’s concession that its adversary complaint is only “related to a case under chapter 11,” I hold that Durango’s current adversary complaint is not a core proceeding.
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Section 157(b)(2)(B) treats the allowance or disallowance of claims against the bankruptcy estate as a core proceeding.

Buena Vista Television v. Adelphia Communications Corp. (In Re Adelphia Communications Corp.) · filed 2004-03-30(b)(2)(B)

That conferred jurisdiction upon the bankruptcy court to consider the Copyright Owners’ claims as a core matter, under both the express language of 28 U.S.C. § 157(b)(2)(B), and the more generalized caselaw addressing the nature of core matters.
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Filing a proof of claim places the allowance or disallowance of that claim within the bankruptcy court’s core jurisdiction.

Tallo v. Gianopoulos · filed 2005-02-16(b)(2)(B)

The debtors correctly contend in the present motion that the filing of the proof of claim placed Tallo’s claims within the bankruptcy court’s core jurisdiction.
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Section 157(b)(2)(B) treats determinations of claims against the estate as core bankruptcy proceedings.

In Re Murdock · filed 2005-11-22(b)(2)(B)

It is a fundamental function of bankruptcy law, and a “core” area of a bankruptcy court’s jurisdiction, to make determinations regarding claims against the estate.
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Section 157(b)(2)(B) makes a contract claim a core proceeding when its resolution affects whether, or in what amount, a creditor may recover on its proof of claim.

Shubert v. Lucent Technologies Inc. (In Re Winstar Communications, Inc.) · filed 2005-12-21(b)(2)(B)

Whether Lucent may have breached the Subcontract by refusing to pay the March 2001 spreadsheet has a direct bearing upon whether Lucent may recover under its Proof of Claim and if so, in what amount. Therefore the breach of the Subcontract claim falls within the core jurisdiction of the Court. 28 U.S.C. § 157(b)(2)(B).
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Section 157(b) permits a bankruptcy court to adjudicate allowance of a postpetition attorney-fee claim payable from property subject to distribution under a confirmed plan.

Bennett & Fairshter v. Stinky Love, Inc. (In Re Lacy) · filed 2006-01-06(b)

BF maintains that payment of the Postpetition Fee Claim may be made from funds that it might recover in the Old Standard Suit, which, based on uncontested evidence, the bankruptcy court found would be property subject to distribution under the debtor’s confirmed plan. This being so, the bankruptcy court had jurisdiction to adjudicate the allowance of the Postpetition Fee Claim under §§ 327, 328, 329 and 330, and 28 U.S.C. §§ 157(b) and 1334(b).
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Section 157(b)(2)(B) treats determinations of exemptions from bankruptcy estate property as core proceedings in which a bankruptcy court may enter final orders.

In Re Toland · filed 2006-03-06(b)(2)(B)

Determinations as to exemptions from property of the bankruptcy estate are core proceedings over which this Court has been conferred with the jurisdictional authority to enter final orders. 28 U.S.C. §§ 157(b)(2)(B) & 1334.
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Section 157(b)(2)(B) treats a proceeding that is essentially a claim against the bankruptcy estate as a core proceeding in which the bankruptcy court may enter a final order or judgment.

Grady v. Quantegy, Inc. (In Re Quantegy, Inc.) · filed 2006-03-17(b)(2)(B)

Further, because this adversary proceeding is essentially a claim against the bankruptcy estate, this is a core proceeding under 28 U.S.C. § 157(b)(2)(B) thereby extending this court’s jurisdiction to the entry of a final order or judgment.
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Section 157(b)(2)(C) treats an estate’s counterclaim against a creditor that filed a claim as a core proceeding.

Cooley v. Wells Fargo Financial (In Re Cooley) · filed 2007-02-14(b)(2)(C)

Thus, this adversary proceeding falls squarely within the definition of one of the categories of core proceedings described in subsection 157(b)(2)(C) of title 28, which states: “Core proceedings include ... counterclaims by the estate against persons filing claims against the estate.”
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Section 157(b)(2)(F) treats a preference avoidance proceeding as a core proceeding that a bankruptcy court may hear and determine.

Peltz v. Merisel Americas, Inc & MOCA (In Re Bridge Information Systems, Inc.) · filed 2008-03-03(b)(2)(F)

This is a core proceeding under 28 U.S.C. § 157(b)(2)(F), which the Court may hear and determine.
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Section 157(b)(2)(E) treats turnover proceedings as core, but an action to collect a disputed prepetition account receivable is noncore even when pleaded as turnover.

DHP Holdings II Corp. v. Home Depot, Inc. (In Re DHP Holdings II Corp.) · filed 2010-09-09(b)(2)(E)

A turnover claim under section 542(b) is core. 28 U.S.C. § 157(b)(2)(E) (core proceedings include, “orders to turn over property of the estate”). ... Therefore, the Court finds that the Debtors’ turnover action is a non-core claim because it seeks to collect a disputed pre-petition account receivable.
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Section 157(b)(2)(B) does not make a prepetition counterclaim against a debtor a core proceeding merely because the claimant may later file a proof of claim.

Legal Xtranet, Inc. v. AT & T Management Services, L.P. (In Re Legal Xtranet, Inc.) · filed 2011-05-24(b)(2)(B)

Despite LXI’s assertion that AT & T would have to eventually file a proof of claim to preserve its rights in the bankruptcy court, that eventuality is insufficient to deem AT & T’s counterclaims core at this time.
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Section 157(b)(2)(B) treats contract claims as core when resolving them necessarily involves deciding proofs of claim against the estate.

Walter v. Freeway Foods, Inc. (In Re Freeway Foods of Greensboro, Inc.) · filed 2011-05-24(b)(2)(B)

A determination of the rights of the parties under the Lease will necessarily involve a resolution of the proofs of claim filed by Walter, Waffle House, and YSI. These causes of action are core.
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Section 157(b)(2) permits a bankruptcy court to determine common law claims to the extent necessary to allow or disallow creditors’ proofs of claim.

Picard Ex Rel. Bernard L. Madoff Investment Securities, LLC v. Estate of Madoff · filed 2011-12-22(b)(2)

Under Stem, the bankruptcy court retains authority to determine all of the Trustee’s common law claims to the extent that it must do so to determine the allowance or disallowance of Mark and Andrew’s proofs of claim.
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Section 157(b)(2)(B) gives bankruptcy courts core jurisdiction to determine a creditor’s claim when the creditor files a proof of claim.

Kraken Investments Ltd. v. Jacobs (In re Salander-O'reilly Galleries, LLC) · filed 2012-07-10(b)(2)(B)

Further, Kraken has filed a proof of claim in this case, thus triggering core jurisdiction under 28 U.S.C. § 157(b)(2)(B) for “allowance or disallowance of claims against the estate.”
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Section 157(b)(2)(B) treats allowance or disallowance of claims against the estate as a core proceeding that a bankruptcy court may finally adjudicate.

Hamilton v. Try Us, LLC · filed 2013-05-01(b)(2)(B)

The fact that Congress did not create the cause of action asserted by Realeo removes this possibility, but it does not mean that section 157(b)(2)(B) is not constitutional under Katchen and Langenkamp. ... The Court concludes Article III permits bankruptcy judges to adjudicate legal and factual disputes related to claims filed against a bankruptcy estate. ... Therefore, the Bankruptcy Court’s resolution of Realco’s claim (and Debtor’s defenses) did not violate Article III of the Constitution.
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Section 157(b)(2)(B) treats an order resolving a significant homestead exemption issue as a core proceeding order.

William Paul, Jr. v. Allred · filed 2014-01-13(b)(2)(B)

An order resolving a significant homestead exemption issue is a core proceeding order, see 28 U.S.C. § 157(b)(2)(B), which “is immediately appealable under 28 U.S.C. § 158(d).”
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Section 157(b)(2)(B) treats objections to claims as core proceedings within the bankruptcy court’s jurisdiction.

400 Walnut Associates, L.P. v. 4th Walnut Associates L.P. (In re 400 Walnut Associates, L.P.) · filed 2014-03-12(b)(2)(B)

As this matter involves an objection to a claim, it is within this Court’s core jurisdiction.
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Section 157(b)(3) bars a court from finding a proceeding noncore solely because state law may affect its resolution.

Schultze v. David Chandler, Sr. · filed 2014-08-01(b)(3)

Plaintiffs argue that their action cannot be a core proceeding because it is predicated on state law. However, the governing statute clearly states that “[a] determination that a proceeding is not a core proceeding shall not be made solely on the basis that its resolution may be affected by State law.” 28 U.S.C. § 157(b)(3).
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Section 157 lists allowance and disallowance of claims against a bankruptcy estate as core proceedings.

Vuksich v. Imaging3, Inc. (In Re Imaging3, Inc.) · filed 2015-12-17(b)(2)(B)

The bankruptcy court’s disallowance of Vuksich’s claims for stock loss and legal fees did not violate the rule announced in Stern v. Marshall, 131 S. Ct. 2594 (2011). Allowance and disallowance of claims against an estate are specifically listed as “core” proceedings under 28 U.S.C. § 157. Moreover, in contrast to the debtor’s state law counterclaim against a creditor in Stern, Vuksich’s claims for “stock loss” and “attorney’s fees” were claims directly against the bankruptcy estate. By filing proofs of claim, Vuksich invoked the bankruptcy court’s jurisdiction.
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Section 157(b)(2)(B) treats liquidation of a creditor’s claim against the debtor’s estate as a core proceeding, even when the creditor seeks to arbitrate the claim.

In re Patriot Solar Group, LLC · filed 2017-06-26(b)(2)(B)

The liquidation of Vanguard’s claims against the Debtor through arbitration would clearly be a core proceeding.
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Section 157(b)(2)(B) treats a proceeding that determines the allowance or disallowance of claims against a bankruptcy estate as a core proceeding.

Kitts v. Cashco, Inc., a New Mexico Corporation · filed 2019-07-31(b)(2)(B)

In sum, the Court concludes that Plaintiff’s claims against Cashco and Budget fall within § 157(b)(2)(B) making the Class Action Adversary Proceeding a core proceeding as to those claims.
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Section 157(b)(2)(B) authorizes a bankruptcy court to determine the amount of a debt when the debtor objects to a filed proof of claim.

Bioconvergence LLC v. Attariwala · filed 2020-06-23(b)(2)(B)

The debtor has objected to Singota’s proof of claim, and this court clearly has the authority to determine the amount of the debt under 28 U.S.C. § 157(b)(2)(B).
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Section 157(b)(2) treats proceedings concerning estate administration and objections to claims as core proceedings in which the bankruptcy court may enter a final order.

In re: SKYLINE RIDGE, LLC · filed 2021-08-25(b)(2)

Moreover, Cinco's settlement also resolved Debtor's objection to Cinco's proof of claim, which directly concerned the administration of the estate, both "core" proceedings under 28 U.S.C. § 157(b)(2)(A) & (B). Accordingly, the bankruptcy court had jurisdiction to enter the Confirmation Order, which effectively and finally resolved the suit.
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Section 157(b)(2)(B) treats liquidation of a claim against the debtor as a core proceeding within the bankruptcy court's jurisdiction.

Manchester v. Kretchmar (In re Kretchmar) · filed 2018-10-05(b)(2)(B)

A claim to liquidate a debt against a debtor is a core proceeding over which this Court should exercise jurisdiction, 28 U.S.C. § 157(b)(2)(B) ; In re Hirsch , 339 B.R. 18, 25 (E.D.N.Y. 2006) ("The estimation of allowance or disallowance of claims against a debtor's estate are core proceedings over which a bankruptcy court has jurisdiction.").
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Section 157(b)(2)(B) treats allowance or disallowance of claims against the estate as a core proceeding even when the claimant has not filed a proof of claim.

Hawkes v. Automated Recovery Systems Of New Mexico, INC. a N · filed 2023-02-02(b)(2)(B)

§ 157(b)(2)(B) provides that a core proceeding includes “allowance or disallowance of claims against the estate. . .” It does not say “proofs of claim.”
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Section 157(b) treats allowance of professional fees as a core proceeding, but collection of allowed fees from the debtor is not core.

Bartley Industries Inc · filed 2023-02-02(b)

The Court undisputably has jurisdiction over fee applications after dismissal. “The Tenth Circuit has held that bankruptcy courts retain jurisdiction after case dismissal over pending ‘core proceedings,’” and “[a]llowance of professional fees is a ‘core’ proceeding,” In re Salazar, No. 15-13194 TS13, 2016 WL 7377043, at *3 (Bankr. D. N.M. Dec. 19, 2016) (first citing Johnson yv. Smith (In re Johnson), 575 F.3d 1079, 1083 (10% Cir. 2009) (bankruptcy court retained Jurisdiction to hear “core” adversary proceeding after dismissal of the main case); then citing Smith v. Commercial Banking Corp. (In re Smith), 866 F.2d 576, 578 (3d Cir. 1989) (to the same effect); then citing Fidelity & Deposit Co. of Maryland v. Morris (In re Morris), 950 F.2d 1531, 1534 (11 Cir. 1992) (same); and then citing 28 U.S.C. § 157(b)(2)(A) and (B)). However, “(c]ollection of allowed professional fees from the debtor is not a core proceeding,” Salazar, 2016 WL 7377043, at *4; see also 28 U.S.C. § 157(b). Thus, jurisdiction over Sisson’s collection efforts is not clear cut, and the Court must examine the extent of its ancillary jurisdiction.
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Section 157(b)(2)(B) limits a bankruptcy court’s core jurisdiction over claim allowance to claims against the estate.

In re: Booker Theodore Wade, Jr. · filed 2015-11-17(b)(2)(B)

By statute, the bankruptcy court’s core jurisdiction extends only to the “allowance or disallowance of claims against the estate . . . .” 28 U.S.C. § 157(b)(2)(B) (emphasis added).
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Counterclaims and setoff as core proceedings

Section 157(b)(2)(C) treats a debtor’s counterclaim against a creditor who filed a proof of claim as a core proceeding; the bankruptcy court may finally decide it when resolving the counterclaim is part of deciding that claim.

Cadaner v. Johnson · filed 2025-06-13(b)(2)(C)

A debtor’s counterclaims against a creditor that filed a proof of claim are statutorily core proceedings. ... A debtor’s counterclaims, however, are constitutionally core only if the counterclaims are resolved in the process of determining the creditor's proof of claim.
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Section 157(b)(2)(C) classifies an estate’s counterclaim against a creditor as a core proceeding, but that classification does not by itself prevent arbitration.

Slipped Disc Inc. v. CD Warehouse Inc. (In Re Slipped Disc Inc.) · filed 2000-02-14(b)(2)(C)

While the present adversary proceeding is indeed a core proceeding under § 157(b)(2)(C), it is not a core proceeding in the same manner as that term is used in cases dealing with enforcement of arbitration clauses.
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Section 157(b)(2)(C) does not make a debtor’s action as plaintiff a core proceeding when the action and counterclaims were brought before the bankruptcy estate existed.

Bowen Corp. v. Security Pacific Bank Idaho, F.S.B. · filed 1993-02-19(b)(2)(C)

There is no logic by which the language of (C), requiring a counterclaim by the estate against a party asserting a claim against the estate, can be twisted to include an action in which the debtor is a plaintiff, and both the action and defendants’ counterclaims were brought before a bankruptcy estate was in existence.
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Section 157(b)(2) covers a lender liability counterclaim against a creditor that filed a claim against the estate and a lender liability claim affecting liquidation of estate assets or the debtor-creditor relationship.

Matter of Baudoin · filed 1993-01-06(b)(2)(C), (b)(2)(O)

We hold that the Baudoins' lender liability claim falls squarely within the provisions of 28 U.S.C. § 157(b)(2) and, as such, would have been a "core proceeding" in both the corporate and personal bankruptcies.
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Section 157(b)(2)(O) treats an equitable subordination action concerning a secured creditor’s claim as a core proceeding that adjusts the debtor-creditor relationship.

In Re Osborne · filed 1984-09-18(b)(2)(O)

The instant equitable subordination action is clearly a "core" proceeding as defined by the Act. In it, the general creditors seek the court-ordered subordination of the claim of a secured creditor. It thus falls within 28 U.S.C. § 157(b)(2)(O), which includes among "core" proceedings "other proceedings affecting the liquidation of the assets of the estate or the adjustment of the debtor-creditor or the equity security holder relationship, except personal injury tort or wrongful death claims."
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Section 157(b)(2)(O) includes an action by general creditors to subordinate a secured creditor’s claim among core proceedings.

Bank of New Richmond v. Production Credit Ass'n of River Falls, Wisconsin · filed 1984-09-18(b)(2)(O)

The instant equitable subordination action is clearly a “core” proceeding as defined by the Act. In it, the general creditors seek the court-ordered subordination of the claim of a secured creditor. It thus falls within 28 U.S.C. § 157(b)(2)(0), which includes among “core” proceedings “other proceedings affecting the liquidation of the assets of the estate or the adjustment of the debtor-creditor or the equity security holder relationship, except personal injury tort or wrongful death claims.”
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Section 157(b)(2)(C) allows a bankruptcy judge to hear debtor claims against a party that filed a proof of claim against the estate.

Marketing Resources International Corp. v. PTC Corp. (In Re Marketing Resources International Corp.) · filed 1984-09-28(b)(2)(C)

PTC has filed a proof of claim against the estate and thus under § 157(b)(2)(C) we have jurisdiction to address all claims brought by the debtor against PTC.
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Section 157(b)(1) and (2) allows the bankruptcy court to adjudicate this creditor’s claims and the related counterclaims as core proceedings.

Jefferson National Bank v. I.A. Durbin, Inc. (In Re I.A. Durbin, Inc.) · filed 1985-05-28(b)(1) and (2)

The Court has jurisdiction over Jefferson, Durbin and Mrs. Kail and of the subject matter of this adversary proceeding and the counterclaims as core proceedings as provided by 28 U.S.C. § 157(b)(1) and (2).
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Section 157(b)(2)(C) treats an estate’s counterclaim against a creditor as a core proceeding when it is logically connected to the creditor’s claim.

Lombard-Wall Inc. v. New York City Housing Development Corp. (In Re Lombard-Wall Inc.) · filed 1985-04-04(b)(2)(C)

Judge Ryan considered these factors and then correctly concluded that “the LC issue is so logically connected to the proof of claim that judicial economy and fairness dictate they be decided in the same forum.” 44 B.R. at 936. The Lombard action is a core proceeding within the meaning of 28 U.S.C. § 157(b)(2)(C) and, as such, is subject to the bankruptcy court’s jurisdiction.
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A defendant’s counterclaims against the estate can give a bankruptcy judge authority under § 157(b)(2)(C) to decide the estate’s claims against that defendant and enter a final order.

Brodsky v. Schnepper (In Re Gross) · filed 1985-04-29(b)(2)(C)

We hold that these counterclaims constitute claims against the estate under § 157(b)(2)(C) which give us jurisdiction to ... adjudicate these causes of action as well as the debtor’s case in chief against Schnep-per. We may consequently enter a final order disposing of the controversy.
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Section 157(b)(2)(C) treats an estate’s suit against a party that filed a claim against the estate as a core counterclaim.

In Re Wood · filed 1985-06-25(b)(2)(C)

Since the Commission filed a claim in Mr. Wood’s Chapter 7 case, the Trustee’s suit is clearly a counterclaim under 28 U.S.C. Section 157(b)(2)(C) (1984).
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Section 157(b)(2)(C) treats an estate’s set-off claim against a creditor who filed a proof of claim as a core proceeding.

Westside Utilities, Inc. v. Robert E. Ratliff Co. (In Re Westside Utilities, Inc.) · filed 1985-08-27(b)(2)(C)

This is a core proceeding as defined in 28 U.S.C. § 157(b)(2)(C), inasmuch as the Defendant has filed a proof of claim against this estate as a secured creditor in the sum of $120,506.46, and the plaintiffs complaint seeks a set-off against said claim.
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Section 157(b)(2)(C) treats equitable subordination as a core proceeding because it directly affects liquidation of estate assets.

Henderson v. Buchanan (In Re Western World Funding, Inc.) · filed 1985-09-05(b)(2)(C)

Equitable subordination directly affects the liquidation of the assets of the estate, and hence is a core proceeding pursuant to § 157(b)(2)(C)).
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Section 157(b)(2) treats disputed claims against the estate and counterclaims as core proceedings.

Ellwood City Iron & Wire Co. v. Flakt, Inc. (In Re Ellwood City Iron & Wire Co.) · filed 1986-02-12(b)(2)(B), (b)(2)(C)

A disputed claim is unquestionably a core matter, 28 U.S.C. § 157(b)(2)(B). A counterclaim is also a core matter, 28 U.S.C. § 157(b)(2)(C).
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A dispute over a credit union’s setoff of debtors’ deposit is a core bankruptcy proceeding under § 157(b)(2)(E).

Frederick v. America's First Credit Union (In Re Frederick) · filed 1986-02-13(b)(2)(E)

This cause is before the Court on the Debtors’ complaint and subsequent motion for summary judgment contesting the Defendant’s setoff of the Debtors’ credit union deposit. Jurisdiction lies pursuant to 28 U.S.C. § 1334. This matter is a core proceeding. 28 U.S.C. § 157(b)(2)(E).
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Section 157(b)(2)(C) treats an estate’s counterclaim against a person who has asserted a claim against the estate as a core proceeding; a defendant’s counterclaim against an estate that sued first does not qualify.

Gross v. Schnepper · filed 1986-06-04(b)(2)(C)

The language of § 157(b)(2)(C) provides that the kind of counterclaim constituting a core proceeding is one filed by the estate against a person who has asserted a claim against the estate. ... Here, the estate initiated the action and defendant counterclaimed against the estate. Accordingly, this matter is a related matter, not a core proceeding.
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Section 157(b)(2)(C) treats a debtor’s adversary complaint that functions as a counterclaim to a creditor’s proof of claim as a core proceeding.

Bedford Computer Corp. v. Ginn Publishing, Inc. (In Re Bedford Computer Corp.) · filed 1986-06-19(b)(2)(C)

I therefore rule that pursuant to 28 U.S.C. § 157(b)(2)(C), this adversary proceeding is a “core proceeding” and this court accordingly has “core” jurisdiction.
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Section 157(b)(2)(C) treats an estate’s counterclaim arising from the same transaction as a creditor’s filed claim as a core proceeding.

Colvard v. Gulf States Drilling Co. (In Re Bar M Petroleum Co.) · filed 1986-07-15(b)(2)(C)

The Court holds that this is the sort of counterclaim, arising out of the same transaction as Defendant’s claim, that falls within § 157(b)(2)(C) as a core proceeding.
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Section 157(b)(2)(C) treats a debtor’s counterclaims against parties that filed claims against the estate as core proceedings, including state-law counterclaims arising from the same transaction.

Long Island Lighting Co. v. Bokum Resources Corp. (In Re Bokum Resources Corp.) · filed 1986-09-08(b)(2)(C)

Since the counterclaims filed by Bokum are against persons filing claims against the estate, they fall squarely within the language of 28 U.S.C. § 157(b)(2)(C).
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Section 157(b)(2) covers the trustee’s claims and closely related crossclaims and counterclaims as core proceedings when they share factual issues and the trustee’s proceeding directly affects them.

Schwarz v. Equitable Bank, N.A. (In Re Express Liquors, Inc.) · filed 1986-10-17(b)(2)

The trustee’s causes of action are core proceedings pursuant to 28 U.S.C. § 157(b)(2)(E), (F), (H), and (O). The court also considers the related crossclaims and the counterclaims to be core proceedings as well since those causes of action have many overlapping factual issues, are closely related to the claims brought by the trustee, and are directly affected by the outcome of the trustee’s proceeding.
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Section 157 treats an estate’s counterclaim against a creditor who filed a claim as a core proceeding.

Caughlan v. First Security Bank of Helena (In re Chadwick) · filed 1986-11-05(b)(2)(C)

Finally, with the Proof of Claim of the Bank still on file, the action by the Trustee is certainly in the nature of a counterclaim against that claim. As such, a core matter is presented under Section 28 U.S.C. 157(c) (counterclaims by the estate against persons filing claims against the estate).
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Section 157(b)(2)(A) and (C) classify this proceeding over obligations owed to a Chapter 11 estate as core.

McDonald v. Dabbagh (In Re Perret) · filed 1986-12-02(b)(2)(A), (C)

This is a core proceeding under 28 U.S.C. § 157(b)(2)(A) and (C).
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Section 157 permits a bankruptcy judge to hear and determine a debtor’s counterclaim arising from the same contract as the government’s adversary complaint, despite the Contract Disputes Act’s procedures.

United States v. MacLeod Co. (In Re MacLeod Co.) · filed 1986-11-19(b)(2)(C)

In a carefully worked-out scheme, then, Congress has depicted appropriate jurisdiction for the bankruptcy court. We hold that that scheme confers jurisdiction upon us to hear and determine debtor’s counterclaims in this case and, further, that the Contract Disputes Act, 41 U.S.C. § 601 et seq., (1982), does not mandate a different result.
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Section 157(b)(2)(C) treats an estate’s counterclaim against a creditor who has filed a claim as a core proceeding.

Sun West Distributors, Inc. v. Grumman Energy System Co. (In Re Sun West Distributors, Inc.) · filed 1987-02-09(b)(2)(C)

Under the language of 28 U.S.C. § 157(b)(2), this action is a core proceeding. Debtor commenced this proceeding as a counterclaim against Grumman, who has filed a claim based on contract against the estate. Section 157(b)(2)(C) specifically defines as core proceedings counterclaims by the estate against persons filing claims against the estate.
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A counterclaim by the estate against a creditor’s claim is a core proceeding when it arises from the same sales and services as the creditor’s proof of claim, even if it was not filed directly in response to that proof of claim.

Southern States Cooperative, Inc. v. Townsend Grain & Feed Co. (In Re L.B. Trucking, Inc.) · filed 1987-06-09(b)(2)(C)

Although the counterclaim was not filed directly in response to the proof of claim, it was filed subsequent to it and arises from the same sales and services that give rise to the proof of claim. ... As such it falls within the definition of a core proceeding. 28 U.S.C. § 157(b)(2)(C).
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Section 157(b)(2)(C) includes an estate’s counterclaims against a creditor that filed a claim among the core proceedings a bankruptcy court may hear.

Oneida Motor Freight v. United Jersey Bank · filed 1987-07-06(b)(2)(C)

As an initial matter, the bankruptcy court would have had subject matter jurisdiction to hear Oneida’s state law claims. A bankruptcy court may hear “all core proceedings arising under title 11, or arising in a case under title 11.” 28 U.S.C. § 157(b)(1). “Core proceedings” specifically include “counterclaims by the estate against persons filing claims against the estate.” 28 U.S.C. § 157(b)(2)(C).
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Section 157(b)(2)(C) treats an estate’s compulsory counterclaim arising from the same transaction as a creditor’s claim against the estate as a core proceeding.

Taubman Western Associates, No. 2 v. Beugen (In Re Beugen) · filed 1988-01-26(b)(2)(C)

Because Debtor David E. Beugen’s counterclaim against Creditor Taubman is a compulsory counterclaim arising from the same transaction as Taubman’s claim against Beugen, there is no right to jury trial on Beugen’s counterclaim, and that counterclaim may be tried as a core proceeding under 28 U.S.C. § 157(b)(2)(C).
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Section 157(b)(2)(C) covers a debtor’s claim against a creditor as a core counterclaim when the creditor has a claim against the bankruptcy estate.

Williams v. Associates Finance, Inc. (In Re Williams) · filed 1988-06-23(b)(2)(C)

Resolution of the Williams’ adversary would, nevertheless, give rise to a core proceeding. Williams’ claim against the Defendants is a counterclaim for purposes of 28 U.S.C. § 157(b)(2)(C).
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Section 157(b)(2)(C) treats an estate’s damages claim against a creditor that filed a claim as a core counterclaim, even when local procedure requires filing it as a complaint.

Pro MacHine, Inc. v. Hardinge Bros. (In Re Pro MacHine, Inc.) · filed 1988-07-25(b)(2)(C)

Debtor’s claim for damages also is properly categorized as a core proceeding under 28 U.S.C. § 157(b)(2)(C), which makes counterclaims by the estate against persons filing claims against it, core proceedings. Debtor’s claim for damages is couched as a complaint rather than counterclaim only because Local Rule 114(f) requires counterclaims against a claimant to be asserted by complaint in an adversary proceeding, with any objection to the claim included in the complaint.
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Section 157(b)(2)(C) treats counterclaims by the estate against persons who filed claims against the estate as core proceedings.

Kraus-Thomson Organization, Ltd. v. McCorhill Publishing, Inc. (In Re McCorhill Publishing, Inc.) · filed 1988-09-07(b)(2)(C)

Indeed, 28 U.S.C. § 157(b)(2)(C) explicitly defines a core proceeding to include “counterclaims by the estate against persons filing claims against the estate.”
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A debtor’s damages action does not become a core proceeding merely because recovery would increase the bankruptcy estate.

T.R. Paris & Family, Inc. v. First National Bank in Robinson (In Re T.R. Paris & Family, Inc.) · filed 1988-08-18(b)(2)(C)

While a recovery on debtors’ complaint would increase the amount of property of debtors’ estate subject to administration in bankruptcy, this factor alone is insufficient to render the action a core proceeding under § 157.
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Section 157(b)(1) permits a bankruptcy court to decide a creditor’s compulsory counterclaim as a core proceeding when the creditor has filed a proof of claim and the counterclaim is integral to the bankruptcy case.

Kroh Bros. Development Co. v. Bazan (In Re Kroh Bros. Development Co.) · filed 1988-10-07(b)(1)

Both Bazan and Chocolate Soup, Inc., filed a proof of claim in this case on February 11, 1988, therefore, they have consented to try their compulsory counterclaim as a core proceeding. Because of its integral connection to the bankruptcy case, this Court finds that defendants’ counterclaim is a core proceeding.
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A counterclaim to a proof of claim is a core proceeding under § 157(b)(2)(C).

Dechert Price & Rhoads v. Direct Satellite Communications, Inc. (In Re Direct Satellite Communications, Inc.) · filed 1989-02-06(b)(2)(C)

The parties apparently agree, and we previously stated in each of our prior Mem-oranda, 91 B.R. at 8, 91 B.R. at 6, 86 B.R. at 391, that the instant proceeding is properly classified as a counterclaim to a proof of claim, and hence is a “core proceeding” pursuant to 28 U.S.C. § 157(b)(2)(C).
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Section 157(b)(2)(C) classifies an estate’s counterclaim against a party that filed a proof of claim as a core proceeding.

Frymire v. Painewebber, Inc. (In Re Frymire) · filed 1989-02-10(b)(2)(C)

It therefore ... may be classified as a core proceeding pursuant to 28 U.S.C. § 157(b)(2)(C).
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Section 157(b)(2)(C) classifies a debtor’s counterclaim to a filed proof of claim as a core proceeding that the bankruptcy court may determine.

222 Liberty Associates v. EESCO Electric, Inc. (In Re 222 Liberty Associates) · filed 1989-06-23(b)(2)(C)

The Complaint therefore takes the form of a counterclaim to a proof of claim, which is classifiable as a core proceeding which we can determine under 28 U.S.C. §§ 157(b)(1) and (b)(2)(C).
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Section 157(b)(2)(C) treats an estate’s counterclaim against a person who filed a claim against the estate as a core proceeding.

Frymire v. PaineWebber, Inc. · filed 1989-11-01(b)(2)(C)

Because plaintiffs action was in the form of a “counterclaim[ ] by the estate against persons filing claims against the estate,” 28 U.S.C. § 157(b)(2)(C), the action fell within the definition of a “core proceeding,” ... and the bankruptcy court retained jurisdiction.
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Section 157(b)(2)(C) does not make a debtor’s separate suit a core counterclaim when the defendant’s proofs of claim were previously waived and disallowed.

In Re New York City Shoes, Inc. · filed 1991-01-03(b)(2)(C)

Here, however, Debtor’s complaint was filed almost a year after Margolis’ proofs of claim were waived and disallowed as part of a settlement of all claims between Margolis and Debtor. Debtor did not file a counterclaim; it initiated a new suit.
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Section 157(b)(2)(C) does not make a debtor’s state-law contract action a core counterclaim merely because the opposing party separately seeks injunctive relief against the debtor.

Marston Enterprises, Inc. v. Krupp Mortgage Co. (In Re Baltic Associates) · filed 1993-01-07(b)(2)(C)

As such, we find that the debtor plaintiffs’ state law breach of contract actions cannot be characterized as “counterclaims” to defendant’s request for injunctive relief and therefore are not "core proceedings” under 28 U.S.C. § 157(b)(2)(C).
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Section 157(b)(2)(B) and (C) permit a bankruptcy court to hear and determine a filed creditor claim and the estate’s counterclaim against that creditor.

Continental Financial Resources, Inc. v. Federal Deposit Insurance · filed 1993-01-15(b)(2)(B), (b)(2)(C)

By filing its proof of claim in this Chapter 11 case, the FDIC has submitted the validity and extent of its claim to this Court for determination. Pursuant to § 157(b)(2)(B) the bankruptcy court has jurisdiction to hear and determine the matter of allowance or disallowance of the claim. In addition, pursuant to § 157(b)(2)(C), the bankruptcy court has jurisdiction to hear and determine the counterclaim by the estate against the claimant, which this adversary proceeding presents.
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Section 157(b)(2)(C) does not make an estate’s claim against a creditor a core counterclaim when the proceeding does not determine the creditor’s claim or an objection to it.

Miramar Resources, Inc. v. Webb (In Re Miramar Resources, Inc.) · filed 1994-12-22(b)(2)(C)

According to the literal language of § 157(b)(2)(C), this cannot be a core proceeding because it does not involve a determination of Webb’s proof of interest, proof of claim or any objection to either.
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Law changed since Stern v. Marshall (June 23, 2011) held that § 157(b)(2)(C) cannot authorize final bankruptcy-court judgment on a state-law counterclaim that is not resolved when the court rules on the creditor’s proof of claim.

Section 157(b)(2)(C) treats estate counterclaims against creditors who file proofs of claim as core proceedings that bankruptcy courts may resolve.

Schwinn Plan Committee v. TI Reynolds 531 Ltd. (In Re Schwinn Bicycle Co.) · filed 1995-05-17(b)(2)(C)

For example, by filing a proof of claim, a creditor submits to counterclaims being resolved by the bankruptcy court as core proceedings rather than having such claims be treated as noncore proceedings that can only be finally resolved by the district court. See 28 U.S.C. § 157(b)(2)(C).
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Section 157(b)(2)(C) classifies the debtor’s counterclaims as core proceedings under its literal terms.

Maxwell Macmillan Realization Liquidating Trust v. Aboff (In re Macmillan Inc.) · filed 1995-08-09(b)(2)(C)

The Berlitz counterclaims under a literal reading of 28 U.S.C. § 157(b)(2)(C) are core.
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Section 157(b)(2)(C) classifies a debtor's counterclaims against a claimant as core proceedings.

In Re MacMillan Inc. · filed 1995-08-15(b)(2)(C)

The Berlitz counterclaims under a literal reading of 28 U.S.C. § 157(b)(2)(C) are core.
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Section 157(b)(2)(C) does not make an entire state-law action a core counterclaim when only one of several defendants has filed a claim against the debtor’s estate.

Dean v. American General Finance, Inc. · filed 1996-01-23(b)(2)(C)

In this ease, only the action against AGF could be considered a counterclaim. Accordingly, this action does not fall within § 157(b)(2)(C).
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Law changed since Stern v. Marshall (June 23, 2011) held that § 157(b)(2)(C) does not permit final judgment on a state-law estate counterclaim unless resolving it is necessary to rule on the creditor’s claim; core classification alone is insufficient.

Section 157(b)(2)(C) treats a counterclaim arising from the same transactions as a creditor’s filed claim as a core proceeding on which the bankruptcy court may enter judgment.

Marshall v. Marshall (In Re Marshall) · filed 2000-12-29(b)(2)(C)

The court further found that the counterclaim arose out of the same transactions and occurrences as the claim and the adversary complaint. ... Because this is a core proceeding, the court has power to enter judgment.
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Section 157(b)(2)(C) treats a debtor’s counterclaim against a creditor that filed a proof of claim as a core proceeding.

Videsh Sandiar Nigam Ltd. v. Startec Global Communications Corp. (In Re Startec Global Communications Corp.) · filed 2003-10-16(b)(2)(C)

Moreover, this claim against VSNL for amounts owed constitutes a counterclaim as listed in § 157(b)(2)(C).
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Section 157(b)(2)(C) treats counterclaims by the estate against persons who file claims against it as core proceedings.

Snavely v. Miller · filed 2005-02-07(b)(2)(C)

28 U.S.C. § 157(b)(2)(C) expressly includes “counterclaims by the estate against persons filing claims against the estate” as core proceedings. Mr. Miller’s claims are core proceedings because they are “counterclaims” under 28 U.S.C. § 157(b)(2)(C).
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Section 157(b)(2)(C) treats claims held by the estate against a creditor that filed a proof of claim as core counterclaims.

Bankruptcy Services, Inc. v. Ernst & Young (In Re CBI Holding Co.) · filed 2008-06-16(b)(2)(C)

Nonetheless, the TCW claims qualify as core under the language of § 157(b)(2)(C), because they are “counterclaims by the estate against persons filing claims against the estate.”
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Filing a proof of claim subjects a creditor to the bankruptcy court’s equitable jurisdiction and can make related breach of contract claims core proceedings.

Manchester Inc. v. Lyle (In Re Manchester, Inc.) · filed 2009-06-01(b)(2)(C)

Moreover, because the Lyles subjected themselves to the equitable jurisdiction of the bankruptcy court when they filed the Proofs of Claim, making even the Count I and II breach of contract claims “core” claims in accordance with 28 U.S.C. § 157(b)(2)(c), the Adversary Proceeding should be heard by a bankruptcy court.
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Section 157(b)(2)(B) treats a claim against the estate as a core proceeding, allowing the bankruptcy court to enter final judgment.

Electric MacHinery Enterprises, Inc. v. Hunt Construction Group, Inc. (In Re Electric MacHinery Enterprises, Inc.) · filed 2009-08-28(b)(2)(B)

Clearly, underlying its claim of set-off, HCC is asserting a claim against the Debtor. As such, HCC has invoked the equitable jurisdiction of the bankruptcy court, transforming this proceeding into a core proceeding under 28 U.S.C. § 157(b)(2)(B). Accordingly, this Court concludes that it may enter a final judgment on the merits on all claims in this proceeding.
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Section 157(b)(2)(C) permits a bankruptcy court to enter final judgment on an estate counterclaim against a creditor, but Article III bars final judgment on a state law counterclaim that is not resolved when the creditor’s claim is decided.

Stern v. Marshall · filed 2011-06-23(b)(2)(C)

Although we conclude that § 157(b)(2)(C) permits the Bankruptcy Court to enter final judgment on Vickie’s counterclaim, Article III of the Constitution does not. ... The Bankruptcy Court below lacked the constitutional authority to enter a final judgment on a state law counterclaim that is not resolved in the process of ruling on a creditor’s proof of claim.
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Section 157(b)(2)(C) covers an estate’s counterclaim against a creditor even when the estate brings it in a separate proceeding.

Stoebner v. PNY Technologies, Inc. (In Re Polaroid Corp.) · filed 2011-07-07(b)(2)(C)

28 U.S.C. § 157(b)(2)(C) clearly envisions the "counterclaim” within its scope in the same, broad sense as the Federal Rules of Civil Procedure do — i.e., "any claim that — at the time” when the referent claim is asserted in a court proceeding " — the [referent claimant] has against an opposing party,” Fed. R.Civ.P. 13(a)(1). The difference, of course, is that the "counterclaim” in the bankruptcy context will often be raised in its own proceeding and in the first instance, rather than responsively in a legal proceeding in which the referent claim was raised first.
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Section 157(b)(2)(C) permits bankruptcy courts to hear estate counterclaims against claimants, but they cannot enter final judgment on a state law counterclaim that is separate from the creditor’s claim.

Black, Davis & Shue Agency, Inc. v. Frontier Insurance Co. in Rehabilitation (In re Black, Davis, & Shue Agency, Inc.) · filed 2012-02-02(b)(2)(C)

This Court lacks the authority to render final judgment on Debt- or’s count for defamation because it is a discrete claim both factually and legally from Frontier’s claims for breach of contract.
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Section 157(b)(2)(C) treats an estate counterclaim as core only when resolving the creditor’s proof of claim also resolves the counterclaim.

Berks Behavioral Health, LLC v. St. Joseph Regional Health Network (In re Berks Behavioral Health, LLC) · filed 2012-02-09(b)(2)(C)

In the Court’s view, however, Debtor has the premises reversed. Stern holds that resolving the claim objection must resolve the causes of action in the adversary proceeding for core jurisdiction to exist. That will not occur here.
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Section 157(b)(2)(C) treats a counterclaim by the bankruptcy estate against a person filing a claim against the estate as a core proceeding only when the parties are mutually aligned.

Sergent v. McKinstry ex rel. BD Unsecured Creditors Trust · filed 2012-03-21(b)(2)(C)

The Plaintiff is correct that § 157(b)(2)(C) requires mutuality of parties.
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Section 157(b)(2)(C) treats an estate’s claims against a creditor who filed a claim as statutory core counterclaims even when the estate files them by adversary complaint.

TP, Inc. v. Bank of America, N.A. (In re TP, Inc.) · filed 2012-09-26(b)(2)(C)

This court agrees that TP’s claims against BOA are statutory core claims under § 157(b)(2) because they are counterclaims by the estate against persons filing claims against the estate. These claims were filed via complaint initiating this adversary proceeding but they now function as counterclaims to the claims filed by BOA against the estate.
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Section 157(b)(2)(C) permits a bankruptcy court to enter final judgment on an estate’s counterclaim when resolving the creditor’s proof of claim necessarily resolves the counterclaim.

In Re: Sundale, LTD., f.k.a. Sundale Associates, Ltd. v. Florida Associates Capital Enterprises, LLC · filed 2012-11-29(b)(2)(C)

Because the underlined phrase is included, it must follow that a bankruptcy court would have jurisdiction to enter final judgment on state law counterclaims that are necessarily resolved in the process of ruling on a creditor’s proof of claim.
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Dischargeability of debts as core proceedings

Section 157(b)(2)(I) covers Bankruptcy Court proceedings to determine whether a particular debt has been discharged.

Southern Tier Masonry, Inc. v. Browning · filed 1993-06-17(b)(2)(I)

To the extent that respondent is claiming that the debt represented by the County Court judgment in excess of $18,000 is discharged, his remedy is to file an adversary proceeding in Bankruptcy Court for a declaration in that regard (see, 28 USC § 157 [b] [2] [I]).
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Section 157(b)(2)(I) treats dischargeability actions as core proceedings.

Pennington · filed 2026-04-02(b)(2)(I)

McKee’s Counterclaims against Blackstone are core. ... Dischargeability actions, however, are core matters. 28 U.S.C. § 157(b)(2)(I).
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Section 157(b)(2)(I) treats determinations about the dischargeability of particular debts as core bankruptcy proceedings.

Reiner v. Paneth · filed 2025-09-17(b)(2)(I)

In 28 U.S.C. § 157(b)(2), Congress set forth a nonexclusive list of 16 types of proceedings deemed core to the authority of the bankruptcy court, including, inter alia, “determinations as to the dischargeability of particular debts.” 28 U.S.C. § 157(b)(2)(I). ... Therefore, the Court affirms the bankruptcy court’s determination that this adversary proceeding is a “core proceeding.”
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Section 157(b)(2)(I) treats determinations of the dischargeability of particular debts as core proceedings.

AMPAM Power Plumbing, L.P. v. Capstone Building Corp. (In re AMPAM Power Plumbing, L.P.) · filed 2014-10-28(b)(2)(I)

This is a core proceeding under 28 U.S.C. § 157(b)(2)(I). ... Because this case involves a determination as to the dischargeability of particular claims, this Court has both statutory and constitutional authority to enter a final judgment.
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Section 157(b)(2)(I) permits bankruptcy courts to hear dischargeability determinations but does not empower them to bind a state dismissed from the proceeding on Eleventh Amendment immunity grounds.

Janc v. Coordinating Board for Higher Education (In Re Janc) · filed 2000-08-08(b)(2)(I)

The “solution” the Debtor in this case now proposes is that we should find an implicit grant of jurisdiction in 28 U.S.C. § 157(b)(2)(I) that gives the bankruptcy court not only the jurisdiction to hear determinations of dischargeability, but the power to bind unconsenting states to those determinations. ... We decline to adopt the Debtor’s solution.
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Section 157(b)(2)(I) and (J) classify dischargeability determinations as core bankruptcy proceedings.

Lenke v. Tischler (In Re Lenke) · filed 2000-05-17(b)(2)(I) & (J)

Under 28 U.S.C. § 157(b)(2)(I) & (J), dischargeability determinations are just as core as are automatic stay issues.
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Section 157 permits a bankruptcy court that finds a debt nondischargeable to determine the underlying claim and enter a monetary judgment.

Amsouth Financial Corp. v. Warner (In Re Warner) · filed 1994-06-16(b)(2)(I)

The Court grants a nondisehargeable judgment in favor of AmSouth in the principal amount of $75,000 plus interest. The Court has jurisdiction to award a monetary judgment in this cause. The Sixth Circuit Court of Appeals held that determination of the dischargeability of a debt is a core matter. If the court determines the debt to be non-dischargeable, the court may proceed to determine the merits of the underlying claim.
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Section 157(b) permits a bankruptcy court to determine the amount of a debt and enter a money judgment in a core dischargeability proceeding.

Itano Farms, Inc. v. Currey (In Re Currey) · filed 1993-06-03(b)(2)(I)

Under these facts, the Court finds it has core jurisdiction to enter a final judgment on the issue of the extent of the indebtedness owed by Defendant to Plaintiff, as well as whether that obligation is excepted from discharge. Because it is a core matter, the Court can evidence its decision by entry of an appropriate, enforceable money judgment.
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Section 157(b)(1) permits a bankruptcy court to enter a money judgment in a core dischargeability proceeding.

United States Fire Insurance Co. v. Harris (In Re Harris) · filed 1993-06-14(b)(1)

Moreover, because dischargeability complaints are core proceedings, 28 U.S.C. § 157(b)(2)(I), the bankruptcy court is authorized to enter final orders and decrees in such matters. 28 U.S.C. § 157(b)(1). ... Accordingly, the court will grant a money judgment in favor of plaintiff in the amount of $11,-620.47.
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Section 157(b)(2)(I) permits a bankruptcy court hearing a core dischargeability matter to determine the debt’s amount and defenses to the complaint.

Maneval v. Davis (In Re Davis) · filed 1993-05-26(b)(2)(I)

This matter being a core matter under 28 U.S.C. § 157(b)(2)(I), this Court in addition to the issue of dischargeability may also determine the amount of the indebtedness and the validity of any other defenses to the complaint.
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Section 157 treats a proceeding to determine dischargeability of a debt as a core proceeding.

Winterland Concessions Co. v. Goldzweig (In Re Goldzweig) · filed 1985-08-07

This cause constitutes a core proceeding. 28 U.S.C. § 157.
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Section 157(b)(2)(I) makes determinations about the dischargeability of particular debts core proceedings that a bankruptcy court may hear and determine.

Thorp Credit Inc. of Maryland v. Lee (In Re Lee) · filed 1985-07-03(b)(2)(I)

The instant complaint is a “core proceeding.” arising under Title 11 of the U.S. Code which this Court may hear and determine, and in which this Court may enter appropriate orders and judgments, according to 28 U.S.C. § 157(b)(2)(I): ... Core proceedings are those matters of estate administration over which Congress expressly provided bankruptcy courts jurisdiction in the 1984 amendments.
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Section 157(b)(2)(I) classifies proceedings to determine the dischargeability of particular debts as core proceedings.

Sethi v. Self (In Re Self) · filed 1985-06-03(b)(2)(I)

This matter is a core proceeding as defined in 28 U.S.C. § 157(b)(2)(I).
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Section 157(b)(2) treats a proceeding to determine the dischargeability of a debt as a core proceeding.

Matter of Carpenter · filed 1985-10-01(b)(2)

The Court finds that this is a core proceeding pursuant to 28 U.S.C. § 157(b)(2).
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Section 157(b)(2)(I) treats proceedings to determine the dischargeability of debts as core bankruptcy proceedings.

Cash v. Armstrong (In Re Armstrong) · filed 1985-10-22(b)(2)(I)

This is a core proceeding. 28 U.S.C. § 157(b)(2)(I).
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Section 157(b)(2)(I) treats determinations of the dischargeability of particular debts as core proceedings.

In Re Pritchett · filed 1985-11-27(b)(2)(I)

The court finds this is a core proceeding. 28 U.S.C. § 157(b)(2)(I).
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Section 157(b)(2)(I) treats determinations of the dischargeability of particular debts as core proceedings.

Hudgens v. Hudgens (In Re Hudgens) · filed 1986-01-22(b)(2)(I)

This is a core proceeding as defined in 28 U.S.C. § 157(b)(2)(I); pursuant to 28 U.S.C. § 157(b)(1), the Bankruptcy Judge for this district may hear and determine all core proceedings arising in a case under Title 11 referred under 28 U.S.C. § 157(a), and the Bankruptcy Judge may enter appropriate orders and judgments.
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Section 157 treats a dischargeability proceeding as a core proceeding that a bankruptcy judge may hear and determine and in which the judge may enter judgment.

Masland v. Weiner (In re Weiner) · filed 1986-01-24(b)(2)(I)

This is a core proceeding as defined in 28 U.S.C. § 157(b)(2)(l); pursuant to 28 U.S.C. § 157(b)(1), the Bankruptcy Judge for this district may hear and determine all core proceedings arising in a case under Title 11 referred under 28 U.S.C. § 157(a), and the Bankruptcy Judge may enter appropriate orders and judgments.
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Section 157(b)(2)(I) treats a proceeding to determine whether a debt is dischargeable as a core proceeding that a bankruptcy judge may hear and determine.

George v. Domingue (In Re Domingue) · filed 1986-02-05(b)(2)(I)

This is a core proceeding as defined in 28 U.S.C. § 157(b)(2)(I); pursuant to 28 U.S.C. § 157(b)(1), the Bankruptcy Judge for this district may hear and determine all core proceedings arising in a case under Title 11 referred under 28 U.S.C. § 157(a), and the Bankruptcy Judge may enter appropriate orders and judgments.
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Section 157(b)(2)(I) treats proceedings to determine whether a debt is dischargeable as core proceedings.

Shafer v. Wintrow (In Re Wintrow) · filed 1986-02-12(b)(2)(I)

This is a case arising under 28 U.S.C. § 1334(a) and having been referred to this court is determined to be a core proceeding under 28 U.S.C. § 157(b)(2)(I), in which the plaintiffs, Carlton E. and Arline Z. Shafer, seek to have a debt owed to them by the defendant-debtor, William R. Wintrow, Jr. declared an exception to discharge pursuant to 11 U.S.C. §§ 523(a)(2)(A) and (a)(6).
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Section 157(b)(2)(I) classifies proceedings to determine dischargeability as core proceedings.

Mason Lumber Co. v. Martin (In Re Martin) · filed 1986-02-13(b)(2)(I)

This is a core proceeding under 28 U.S.C. § 157(b)(2)(I).
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Section 157(b)(2)(I) treats proceedings to determine the dischargeability of debts as core proceedings that a bankruptcy court may hear and determine.

First Community Credit Union v. Cullen (In Re Cullen) · filed 1986-05-05(b)(2)(I)

These are “core proceedings” pursuant to 28 U.S.C. § 157(b)(2)(I), which the Court may hear and determine.
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Section 157 treats a proceeding to determine the dischargeability of a debt as a core proceeding.

Harris "Charge It" Systems v. Deloian (In Re Deloian) · filed 1986-03-27

This cause constitutes a core proceeding. 28 U.S.C. § 157.
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Section 157(b)(2)(I) classifies a proceeding to determine whether a debt is dischargeable as a core proceeding.

Oppenheimer v. Reder (Reder) · filed 1986-04-01(b)(2)(I)

This is a core proceeding under 28 U.S.C. § 157(b)(2)(I).
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Section 157 treats a proceeding to determine the dischargeability of a debt as a core proceeding.

Ross v. Cunningham (In Re Cunningham) · filed 1986-04-10

This cause constitutes a core proceeding. 28 U.S.C. § 157.
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Section 157(b)(2)(I) treats a proceeding to determine dischargeability as a core proceeding.

Chrysler Capital Corp. v. Salzman (In Re Salzman) · filed 1986-06-09(b)(2)(I)

This is a core proceeding within the meaning of 28 U.S.C. § 157(b)(2)(I).
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Section 157(b)(2)(I) treats a proceeding to determine the dischargeability of a debt as a core proceeding.

Barwick v. Brewer (In Re Brewer) · filed 1986-06-19(b)(2)(I)

This is a core proceeding within the meaning of 28 U.S.C. § 157(b)(2)(I).
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Section 157(b)(2)(I) treats a proceeding to determine the dischargeability of a debt as a core proceeding.

John Deere Co. v. Iverson (In Re Iverson) · filed 1986-06-20(b)(2)(I)

This proceeding to determine the dischargeability of a debt is a “core proceeding” within the meaning of 28 U.S.C. § 157(b)(2)(I).
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Section 157(b)(2)(I) makes determinations of the dischargeability of particular debts core proceedings in which a bankruptcy judge may enter a final judgment.

Hill v. Snider (In Re Snider) · filed 1986-06-12(b)(2)(I)

28 U.S.C. § 157(b) provides that the bankruptcy judge may enter final judgments in core proceedings and can submit proposed findings of fact and conclusions of law to the district court in a non-core related proceeding. Expressly included by Congress in the list of core proceedings are “determinations as to the dischargeability of particular debts.” 28 U.S.C. § 157(b)(2)(I). Therefore, this Court has the power to enter a final judgment on the merits of the adversary proceedings.
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Notes 1501–1650 of 6,735, oldest cases first.

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