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.

Determination of core proceedings

Section 157(b)(2) classifies avoidance, fraudulent transfer, claim disallowance, and related declaratory judgment claims as core proceedings.

Weinman v. Crowley (In re Blair) · filed 2018-11-09(b)(2)

The avoidance, fraudulent transfer, claim disallowance, and declaratory judgment causes of action are core proceedings under 28 U.S.C. §§ 157(b)(2)(A) (matters concerning administration of the estate), (b)(2)(B) (allowance or disallowance of claims against the estate), (b)(2)(H) (proceedings to determine, avoid, or recover fraudulent conveyances), and (b)(2)(O) (other proceedings affecting liquidation of assets of the estate).
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Section 157(b)(2) treats a proceeding to interpret and enforce a bankruptcy court’s confirmation order as a core matter.

Smith v. Hilton (In re Swan Transp. Co.) · filed 2018-11-16(b)(2)

As noted by the Texas District Court and further discussed below, this matter relates to the interpretation and enforcement of this Court's Confirmation Order and thus constitutes a core matter under 28 U.S.C. § 157(b)(2).
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Section 157(b)(2) treats claims concerning allowance or disallowance of claims against the estate as core proceedings that a bankruptcy court may hear and decide.

Taylor v. Allied Title Lending, LLC (In re Taylor) · filed 2018-11-20(b)(2)

Thus, Counts II and III are core proceedings under 28 U.S.C. § 157(b)(2) such that the Court retains jurisdiction to hear and decide these claims.
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Section 157(b)(2)(B) makes a dispute over a debtor's claim of exemptions from estate property a core proceeding.

In re Painter · filed 2018-12-05(b)(2)(B)

This matter is also core pursuant to 28 U.S.C. § 157(b)(2)(B) because it concerns the Debtor's claim of exemptions from property of the estate.
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Section 157(b)(2)(B) treats a creditor's claim against a debtor as a core proceeding when it asserts the same right of recovery as the creditor's proof of claim.

Ramco Inc. v. Charles Guy Evans & Sons Inc. (In re Charles Evans Trucking Inc.) · filed 2018-12-10(b)(2)(B)

Core proceedings include "allowance or disallowance of claims against the estate." 28 U.S.C. § 157(b)(2)(B). ... The Lawsuit thus asserts the same right of recovery against Evans Trucking as the right asserted by the proof of claim, transforming Ramco's state law cause of action on open account into a proceeding that could arise only in the context of bankruptcy.
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Section 157(b) treats a state-law contract rescission action that can exist outside bankruptcy as a noncore proceeding.

Webster Place Athletic Club, LLC v. Ramco-Webster Place, LLC (In re Webster Place Athletic Club LLC) · filed 2019-02-28(b)

Though purported to be a "core" proceeding, the rescission action is purely a state law issue and is noncore within the meaning of 28 U.S.C. § 157(b).
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Section 157(b)(2) treats proceedings under Bankruptcy Code §§ 542, 543, 547, 548, and 550 as core proceedings; claims that could have been brought before bankruptcy and do not arise under the Code are noncore.

BT Prime Ltd. v. Bos. Techs. Powered By Forexware LLC (In re BT Prime Ltd.) · filed 2019-03-29(b)(2)

The counts arising under §§ 542, 543, 547, 548, and 550 of the Bankruptcy Code are core proceedings. 28 U.S.C. § 157(b)(2)(E), (F), (H), and (O). The remaining counts, which do not arise under the Bankruptcy Code and which might have been brought by the Debtor before the bankruptcy case was commenced, are not core proceedings.
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Section 157(b)(1) permits a bankruptcy court to decide whether a lease terminated before bankruptcy when that issue determines whether the lease may be assumed.

In re: Sakon · filed 2021-01-19(b)(1)

To the contrary, “a determination of the validity of a lease termination for purposes of assumption under 11 U.S.C. § 365(a) is a core proceeding notwithstanding that the crucial issue is whether there has been a breach of contract and proper termination . . . because the determination, although utilizing state law, is integral to the determination of a federal question—may the lease be assumed under 11 U.S.C. § 365(a).” In re Atlas Fire Apparatus, Inc., 56 B.R. 927, 933 (Bankr. E.D.N.C. 1986) (citations omitted). Accordingly, the Bankruptcy Court properly exercised its jurisdiction in deciding whether the lease had terminated pre-petition.
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Section 157 treats actions to determine, avoid, and recover preferences as core proceedings in which the bankruptcy court may enter final judgment.

Corzin v. Emergency Med. Transp., Inc. (In re Myers) · filed 2018-09-28(b)(1), (b)(2)(A), (b)(2)(F)

Actions to determine, avoid, and recover preferences are core proceedings under 28 U.S.C. § 157(b)(1), (b)(2)(A) and (F) and the Court has authority to enter a final judgment.
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Section 157 treats the determination of whether to grant an order for relief in an involuntary bankruptcy case as a core proceeding.

Taberna Preferred Funding IV, Ltd. v. Opportunities II Ltd. (In re Taberna Preferred Funding IV, Ltd.) · filed 2018-11-08(b)(1), (b)(2)(A), (O)

The determination of whether an order for relief should be granted in an involuntary case is a core proceeding pursuant to 28 U.S.C. §§ 157(b)(1) and (b)(2)(A) and (O).
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Section 157(b)(2)(B) treats a claims objection process as a core proceeding.

Jandava Denise Cattron · filed 2022-12-22(b)(2)(B)

The Debtor is correct that such a claims objection process would be a core proceeding. See, e.g., 28 U.S.C. § 157(b)(2)(B).
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Section 157(b)(2) identifies matters that are core proceedings for bankruptcy courts.

Smith v. Race Engines Plus, LLC · filed 2022-12-28(b)(2)

This matter is a core proceeding pursuant to 28 U.S.C. § 157(b)(2).
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Section 157(b)(2)(A) includes matters concerning administration of the bankruptcy estate among core proceedings that bankruptcy courts may hear and determine.

LeClairRyan PLLC · filed 2023-01-05(b)(2)(A)

As the Motion to Amend and the Motion to Authorize “stem[] from the bankruptcy itself or would necessarily be resolved in the claims allowance process,” the claims arising out of these motions are “core proceedings” and the Bankruptcy Court had authority to enter a judgment on the Motions.
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Section 157(b)(2)(A) treats matters concerning administration of the estate as core proceedings.

Patrick S. Layng, United States Trustee for Region v. Barclay · filed 2023-01-10(b)(2)(A)

Furthermore, this is a core proceeding under 28 U.S.C. § 157(b)(2)(A) (matters concerning administration of the estate).
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Section 157(b)(2) permits a debtor’s attorney fee-disclosure dispute to be treated as a core proceeding even though it is not among the listed categories, because the duty to disclose arises only in bankruptcy.

Louie Joseph Aquilino and Robin Aquilino · filed 2023-02-06(b)(2)

There are no enumerated core proceedings within which these issues appear to fall. See 28 U.S.C. § 157(b)(2). However, the disclosure requirements for a debtor’s attorney in a bankruptcy case could only arise in the context of a bankruptcy case — without a bankruptcy case, there would not be a debtor, and the attorney would not have a duty to disclose. Therefore, the Court has core jurisdiction over the Motion to Review.
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Section 157 treats a Rule 9011 sanctions motion as a core proceeding on which the bankruptcy court may enter a final order.

Desarae LaShae Pearson · filed 2023-02-08(b)(2)(A) and (O)

A motion seeking sanctions under Rule 9011 is a core proceeding within the definition of 28 U.S.C. § 157(b)(2)(A) and (O),2 and the Court may enter a final order.
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Section 157 treats a dispute over a claim against the bankruptcy estate as a core proceeding that the bankruptcy court may resolve by final order.

Ronda R Maddox · filed 2023-02-09(b)(2)(B)

The contested matter arising from the Debtor’s Motion to Determine Fees is a “core proceeding” within the meaning of 28 U.S.C. § 157(b)(2)(B), because it involves a claim against ... the estate. Therefore, the court has authority to resolve the contested matter with a final order.
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Section 157 treats motions to approve a property sale and to enforce the sale order as core proceedings.

Kimmel's Coal and Packaging, Inc. · filed 2023-02-17(b)(1), (b)(2)(N)

Both a motion to approve a sale of property and a motion seeking to enforce that order are proceedings “arising under title 11” and are therefore core proceedings.
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Section 157(b) treats a motion to interpret a bankruptcy court’s plan injunction and confirmation order as a core matter within the court’s authority to enforce its orders.

TPC Group Inc. · filed 2023-02-22(b)

Because this Court plainly has jurisdiction to enforce its own orders,15 this is a core matter under § 157(b).
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Section 157(b) treats review of a debtor’s attorney’s bankruptcy fee disclosures as a core proceeding because the disclosure duty arises only in a bankruptcy case.

Louie Joseph Aquilino and Robin Aquilino · filed 2023-02-23(b)

However, the disclosure requirements for a debtor’s attorney in a bankruptcy case could only arise in the context of a bankruptcy case — without a bankruptcy case, there would not be a debtor, and the attorney would not have a duty to disclose. Therefore, the Court has core jurisdiction over the Motion to Review?
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Section 157(b)(2) encompasses a dispute over a debtor’s pre-petition contract when its resolution directly affects estate administration and the validity or priority of liens.

1325 Atlantic Realty LLC v. Brooklyn Hospitality Group LLC · filed 2023-03-22(b)(2)

Resolution of this action therefore directly affects the core bankruptcy functions of administering assets in the bankruptcy estate and determining the validity and priority of liens.
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Section 157(b) treats a bankruptcy court’s determination whether an amended complaint complies with its own injunction as a core matter.

Port Neches Fuels, LLC · filed 2023-04-18(b)

Because the parties ask this Court to determine whether the amended complaint complies with this Court’s injunction, and because this Court plainly has jurisdiction to interpret its own orders,11 this is a core matter under § 157(b).
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Section 157(b)(2)(A) treats a proceeding concerning administration of a debtor’s estate as a core proceeding.

Redstone Advance, Inc. v. Big Daddy Guns, Inc · filed 2023-06-06(b)(2)(A)

Without question, the outcome of this proceeding concerns administration of Debtors’ estates, as provided in 28 U.S.C. § 157(b)(2)(A).
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Section 157(b)(2) covers an adversary proceeding whose resolution is integral to claims adjudication, intertwined with a plan, and significantly affects estate property.

Serta Simmons Bedding, LLC and World of Sleep Outlets, LLC - Adversary Proceeding · filed 2023-06-06(b)(2)

The Adversary is a core proceeding under 28 U.S.C. §§ 157(b)(2)(A), (B), (I), (K), (L) and (O) as its resolution is integral to the claims adjudication process, inextricably intertwined with the Plan and significantly impacts property of the estate.
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Section 157(b)(2) covers an adversary proceeding whose resolution is integral to claims adjudication, intertwined with the plan, and significantly affects estate property.

Serta Simmons Bedding, LLC and World of Sleep Outlets, LLC File only in Remaining Case 23-90024.</f · filed 2023-06-06(b)(2)

The Adversary is a core proceeding under 28 U.S.C. §§ 157(b)(2)(A), (B), (I), (K), (L) and (O) as its resolution is integral to the claims adjudication process, inextricably intertwined with the Plan and significantly impacts property of the estate.
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Section 157(b)(2)(A) treats proceedings concerning administration of the bankruptcy estate as core proceedings that a bankruptcy judge may hear and decide.

Alvaro Flores, Jr. · filed 2023-07-14(b)(2)(A)

This Court determines that pursuant to 28 U.S.C. § 157(b)(2)(A), this proceeding involves primarily core matters as it “concern[s] the administration of the estate.”
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Section 157 permits a bankruptcy judge to finally determine a referred proceeding arising in a bankruptcy case as a core proceeding.

Regina Nachael Howell Foster · filed 2024-05-28(b)

Thus, this Court has jurisdiction to hear and determine the Vexatious Litigant Motion on a final basis as a core proceeding.
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Effect of core status on arbitration and ADR

Section 157(b)(2)(B) treats claim allowance as a core proceeding, but that status alone does not justify overriding a valid arbitration agreement.

EAD Constructors, Inc. · filed 2026-03-05(b)(2)(B)

Although claim allowance is a “core” proceeding, claim allowance does not alone constitute sufficient grounds to override a valid arbitration agreement.
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Section 157(b)(2)(I) classifies proceedings to determine dischargeability as core proceedings, in which a bankruptcy court may decline to compel arbitration when it conflicts with bankruptcy purposes.

Farmer v. Navient Solutions, LLC (In re Farmer) · filed 2017-05-04(b)(2)(I)

As noted above, Farmer’s causes of action seek á determination that her obligation to Navient is dischargeable. The Bankruptcy Code clearly categorizes such claims as core matters. 28 U.S.C. § 157(b)(2)(I). Navient presents no argument to the contrary. Given the core status of Farmer’s claims, this Court has the discretion to weigh the competing bankruptcy and arbitration interests at stake.
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Section 157(b)’s designation of fraudulent conveyance claims as core remains relevant to a bankruptcy court’s discretion to deny arbitration, even when the court may lack authority to enter final judgment.

Kirkland v. Rund (In Re EPD Investment Co.) · filed 2016-05-09(b)(2)(H)

Stern does not affect the statutory designation of matters as core for the purpose of determining whether the bankruptcy court has discretion to deny arbitration because that decision is not itself a final judgment.
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Section 157’s core/non-core classification does not itself give a bankruptcy court discretion to deny enforcement of an arbitration agreement.

In Re: Mintze · filed 2006-01-10

The core/non-core distinction does not, however, affect whether a bankruptcy court has the discretion to deny enforcement of an arbitration agreement.
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A proceeding may be core under § 157(b)(2)(A) and (O), yet the bankruptcy court lacks power to decide disputes subject to mandatory ADR when that process does not jeopardize or inherently conflict with bankruptcy law.

In Re Allegiance Telecom, Inc. · filed 2006-12-08(b)(2)(A) and (O)

The exception, as discussed below, is the Court’s lack of power to decide the parties’ disputes, even though this is a core proceeding under 28 U.S.C. § 157(b)(2)(A) and (O), to the extent that they are subject to mandatory ADR that will not necessarily jeopardize or inherently conflict with the objectives or provisions of the Bankruptcy Code.
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Section 157(b)(2)(E) treats turnover claims as core proceedings.

Pereira v. Urthbox Inc. · filed 2021-08-09(b)(2)(E)

Moreover, a turnover claim is core. See 28 U.S.C. § 157(b)(2)(E).
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Plan confirmation as a core proceeding

Section 157(b)(2)(L) makes confirmation of a bankruptcy plan a core proceeding in which the bankruptcy court may enter a final order or judgment.

In Re Horn · filed 2006-02-23(b)(2)(L)

Further, because the issue involves the confirmation of a plan, this is a core proceeding under 28 U.S.C. § 157(b)(2)(L) thereby extending the court’s jurisdiction to the entry of a final order or judgment.
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Section 157 treats Chapter 11 plan confirmation as a core proceeding in which a bankruptcy judge may enter final judgment.

In re Charles Street African Methodist Episcopal Church · filed 2013-10-02(b)(1), (b)(2)(L)

It is a core proceeding within the meaning of 28 U.S.C. § 157(b)(1). 28 U.S.C. § 157(b)(2)(L) (core proceedings include confirmations of plans). The bankruptcy court accordingly has authority to enter final judgment.
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Section 157(b)(2)(L) treats plan confirmations as core proceedings with final factual findings reviewed for clear error, including confirmations of § 524(g) plans.

In Re: PLANT INSULATION CO. · filed 2013-10-28(b)(2)(L)

The requirement in § 524(g)(3)(A) that the plan be “issued or affirmed by the district court” is insufficient to overcome the plain language of 28 U.S.C. § 157(b)(2)(L) indicating that plan confirmations are final decisions.
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Section 157(b)(2)(L) treats Chapter 13 plan confirmation as a core proceeding that a bankruptcy court may hear and determine.

In re Shelton · filed 2018-09-14(b)(2)(L)

Matters involving confirmation of a debtor's chapter 13 plan may only arise in a bankruptcy case, concern the administration of the bankruptcy estate and are, thus, within the court's core jurisdiction.
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Section 157 treats disputes over plan confirmation as core proceedings that a bankruptcy court may finally decide when they stem from the bankruptcy case.

Key Farms, Inc. · filed 2020-06-23(b)(2)(L)

The parties’ dispute regarding confirmation of the debtors’ proposed plan is statutorily “core”3 and “the action at issue stems from the bankruptcy itself.”4 Accordingly, the court may properly exercise the judicial power necessary to finally decide this dispute.
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Section 157(b)(2)(L) treats confirmation of a proposed plan as a core proceeding that the bankruptcy court may finally decide.

JUAN ANTHONY ZAMORA and Shamika Faye Zamora · filed 2020-07-27(b)(2)(L)

The parties’ dispute regarding confirmation of the debtors’ proposed plan is statutorily “core”35 and “the action at issue stems from the bankruptcy itself.”36 Accordingly, the court may properly exercise the judicial power necessary to finally decide this dispute.
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Section 157(b)(2)(L) classifies plan confirmation as a core bankruptcy proceeding.

Claar Cellars LLC · filed 2021-01-14(b)(2)(L)

The parties’ dispute regarding confirmation of competing plans is statutorily “core”9 and “the action at issue stems from the bankruptcy itself.”10 Accordingly, the court may properly exercise the judicial power necessary to finally decide this dispute.
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Section 157(b)(2)(L) treats disputes over confirmation of a bankruptcy plan as core proceedings.

Astria Health · filed 2021-01-22(b)(2)(L)

The parties’ dispute regarding confirmation of a bankruptcy plan is statutorily “core”11 and “the action at issue stems from the bankruptcy itself.”12 Accordingly, the court may properly exercise the judicial power necessary to finally decide this dispute.
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Section 157(b)(2)(L) treats plan confirmation as a core proceeding in which the bankruptcy court may enter final judgment.

In re Charles Street African Methodist Episcopal Church of Boston · filed 2017-12-14(b)(2)(L)

It is a core proceeding within the meaning of 28 U.S.C. § 157(b)(1). 28 U.S.C. § 157(b)(2)(L) (core proceedings include confirmations of plans). The bankruptcy court accordingly has authority to enter final judgment.
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Section 157(b)(2)(L) treats plan confirmation as a core proceeding, allowing a bankruptcy court to enter a final confirmation order.

Excluded Lenders v. Simmons · filed 2024-12-31(b)(2)(L)

Core proceed- ings include the confirmation of plans. Id. at § 157(b)(2)(L); In re Prescription Home Health Care, Inc., 316 F.3d 542, 547 (5th Cir. 2002). The final order confirmed the Plan, so the bankruptcy court had statutory authority to enter it.
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Section 157 treats plan confirmation as a core proceeding in which a bankruptcy court may enter a final order.

Excluded Lenders v. Simmons · filed 2025-01-21(b)(2)(L)

The final order confirmed the Plan, so the bankruptcy court had statutory authority to enter it.
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Core proceedings—allowance or disallowance of claims

Section 157(b)(2)(B) covers objections to the allowance of a proof of claim, but a dispute over ownership of a claim is not a claim objection.

Launch Pad LLC · filed 2026-03-30(b)(2)(B)

Pemberton is correct that this Court has the jurisdiction to adjudicate an objection to the allowance of a proof of claim. 28 U.S.C. § 157(b)(2)(B). But the question before the Court is not whether the bankruptcy court can adjudicate claim objections. Pemberton filed this Motion as a motion to amend. Pemberton then argued the Motion as a claim objection. But in its essence, the Motion is a dispute over ownership of a claim against the Debtor.
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Section 157(b)(2)(B) treats the allowance or disallowance of claims against the estate as a core proceeding in which the bankruptcy court may enter a final order.

In re Levitt · filed 2006-03-03(b)(2)(B)

Primary among this list is the allowance or disallowance of claims against the estate, which is well within this court’s constitutional powers. 28 U.S.C. § 157(b)(2)(B).
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Law changed since Stern v. Marshall (June 23, 2011) held that § 157(b)(5) allocates trial authority rather than subject matter jurisdiction, so a party may waive the district-court trial right.

Section 157(b)(5) excludes personal injury suits from bankruptcy court jurisdiction and requires them to be tried in district court.

Parker v. Cumming · filed 2007-04-05(b)(5)

Instead, the law is clear that bankruptcy courts have no jurisdiction over personal injury suits.
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Section 157(b)(2)(B) does not make independent state-law claims core proceedings merely because they may affect the bankruptcy estate.

Morris Black & Sons, Inc. v. 23S23 Construction, Inc. (In Re Carriage House Condominiums L.P.) · filed 2009-07-30(b)(2)(B)

Hunter Roberts’ has chosen not to file a proof of claim and has, instead, sought remand of its removed counterclaim. As it stands, its counterclaim (just like the Debtors’ third-party claims against it, as well as the subcontractors claims against the Debtors) would exist independently under non-bankruptcy law. Thus, neither the Hunter Roberts’ counterclaim nor the other causes of action of the subcontractors or the Debtors can be considered “core” proceedings.
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Section 157(b)(2)(B) treats the allowance or disallowance of filed claims as a core proceeding, including determination of the debtor’s liability on the claims.

L. Ardan Development Corp. v. Touhey (In Re Newell) · filed 2010-02-25(b)(2)(B)

Therefore the state court proceedings initiated to determine the debtor’s liability to the plaintiffs come under the bankruptcy court’s core jurisdiction as part of the process of allowance or disallowance of claims.
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Section 157(b)(2)(B) treats matters that are part of the bankruptcy claims allowance process as core proceedings.

South Canaan Cellular Investments, LLC v. Lackawaxen Telecom, Inc. (In Re South Canaan Cellular Investments, LLC) · filed 2010-03-25(b)(2)(B)

In considering first the aiding and abetting claim raised against LTI, as well as the debtors’ objection to LTI’s proofs of claim, I conclude that both are core matters, as they are part of the claims allowance process that could only occur in this bankruptcy case.
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Section 157(b)(2)(B) authorizes bankruptcy courts to decide whether to allow claims against the estate, even when doing so requires applying state law.

In Re Renegade Holdings, Inc. · filed 2010-04-16(b)(2)(B)

Under 28 U.S.C. § 157(b)(2)(B), the allowance or disallowance of claims against the estate is a core proceeding that the bankruptcy court is authorized to hear and determine. The States’ correctly observe that the allowance or disallowance of their claims may involve matters of state law. However, many claims that are filed in bankruptcy cases are based upon or involve state law and bankruptcy courts nonetheless are authorized to rule on the claims, applying state law to the extent necessary. The involvement of state law in the States’ claims thus does not preclude the bankruptcy court from ruling on whether such a claim should be allowed in this case.
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Section 157(b)(2)(B) treats allowance or disallowance of claims against the estate as a core proceeding.

In Re Pierson · filed 2011-03-25(b)(2)(B)

A determination concerning the allowance or disallowance of a claim against the estate is deemed to be a “core proceeding” over which this Court has been conferred with the jurisdictional authority to enter final orders and judgments. 28 U.S.C. § 157(b)(2)(B).
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Section 157(b)(2)(B) classifies matters involving the allowance of claims against a bankruptcy estate as core proceedings.

Alaska Fur Gallery v. First National Bank Alaska (In Re Alaska Fur Gallery Inc.) · filed 2011-09-28(b)(2)(B)

This is a core proceeding pursuant to 28 U.S.C. § 157(b)(2)(B), as it is a matter involving the allowance of claims against the estate.
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Section 157(b)(2)(B) makes the allowance or disallowance of a claim against the bankruptcy estate a core proceeding when a creditor files a proof of claim and the debtor objects.

Continental Insurance v. Thorpe Insulation Co. · filed 2012-01-30(b)(2)(B)

Yet regardless of how Continental characterizes its claim, Continental filed a proof of claim, and Thorpe objected to the claim, so under 28 U.S.C. § 157(b)(2)(B), the allow- ance or disallowance of that claim was a core proceeding.
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A setoff counterclaim asserting a right to payment invokes the claims allowance process and is a core proceeding.

Souther v. Bacon County Health Services Inc. (In re Matrix Imaging Services Inc.) · filed 2012-08-22(b)(2)(B)

By pleading setoff, Bacon County has asserted a “right to payment”—a “claim” under the Bankruptcy Code. The assertion of a claim invokes the claims allowance process, which is a core proceeding under 28 U.S.C. § 157(b)(2)(B).
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Section 157(b)(2)(B) treats allowance or disallowance of claims against the estate as a core bankruptcy proceeding.

In re Pierport Development & Realty, Inc. · filed 2013-05-03(b)(2)(B)

This matter concerns allowance or disallowance of claims against the estate and is therefore a core proceeding under 28 U.S.C. § 157(b)(2)(B).
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Section 157(b)(2)(B) treats an objection to a claim as a core proceeding within the bankruptcy court’s jurisdiction.

In re Deitch · filed 2014-03-12(b)(2)(B)

Because this matter involves an objection to a claim, it is within this Court’s "core” jurisdiction. See 28 U.S.C. § 157(b)(2)(B).
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Section 157(b)(2)(B) makes allowance or disallowance of claims against the estate a core proceeding in which a bankruptcy court may enter a final order.

Northeast Industrial Development Corp. v. ParkStone Capital Partners, LLC (In re Northeast Industrial Development Corp.) · filed 2014-07-29(b)(2)(B)

Accordingly, the Court finds that Count 6 of the Complaint is a core proceeding in which this Court may enter a final order and Counts 1, 2, 3, and 4 are noncore, “related to” proceedings in which the District Court must enter a final order and judgment after de novo review of this Court’s proposed findings of fact and conclusions of law.
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Section 157(b)(2)(B) treats allowance or disallowance of a filed claim as a core proceeding, including resolution of a setoff necessary to determine the claim’s amount.

Prior v. Tri Counties Bank (In re Prior) · filed 2014-10-31(b)(2)(B)

Because the debtor’s claimed setoff must necessarily be adjudicated in the process of allowing or disallowing TCB’s claim, doing so does not create any constitutional limitation on the court’s jurisdiction. Therefore, the court has jurisdiction under the Bankruptcy Code to hear and determine an adversary proceeding which seeks to determine the amount of TCB’s claim filed in the bankruptcy case.
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Section 157(b)(2)(B) treats a proceeding to determine whether a creditor’s loan claim is enforceable as core because it involves allowance or disallowance of claims against the estate.

Moses v. Cashcall, Inc. · filed 2015-03-16(b)(2)(B)

Here, there is no dispute that Moses’ first claim, which seeks to declare that CashCall’s loan is unenforceable, is a statutorily core claim because such an action involves the “allowance or disallowance of claims against the estate.” 28 U.S.C. § 157(b)(2)(B).
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Section 157(b)(2)(B) treats a proceeding to determine the validity of a creditor’s claim against the estate as a core proceeding, even when the creditor has not filed a proof of claim.

Reed v. Zwick (In re Reed) · filed 2016-09-30(b)(2)(B)

Moreover, “allowance or disallowance of claims against the estate” are also core proceedings under 28 U.S.C § 157(b)(2)(B), as are “other proceedings affecting ... the adjustment of the debtor-creditor ..: relationship,” which these are, “except personal injury tort or wrongful death claims,” which these are not, pursu-ant to 28 U.S.C. § 157(b)(2)(0). As al-ready discussed above, the fundamental matters of debt restructuring and dis-charge are at the core of the federal bank-ruptcy power; therefore, ruling on Counts Two and Three as part of allowing or disallowing Navient’s claim against the debtors, absent any demand for affirma-tive relief against Navient, is inherently a core proceeding.
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Section 157(b)(2)(B) makes the allowance of claims a core proceeding, allowing a bankruptcy court to decide issues necessary to determine a foreclosure deficiency claim.

Haugen v. Multibank 2009-1 CRE Venture, LLC (In re Laprade's Marina, LLC) · filed 2017-03-23(b)(2)(B)

Proceedings regarding the allowance of claims are core proceedings arising in a case under title 11. See 28 U.S.C. § 157(b)(2)(B).
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Section 157(b)(2)(B) treats allowance or disallowance of claims against the bankruptcy estate as a core proceeding.

Boyd v. ResCap Borrower Claims Trust (In re Residential Capital, LLC) · filed 2017-10-04(b)(2)(B)

Core proceedings include “allowance or disallowance of claims against the estate.” 28 U.S.C. § 157(b)(2)(B).
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Section 157(b) authorizes bankruptcy courts to hear and finally decide proceedings concerning the allowance or disallowance of claims against the estate.

Daryl Anthony Green · filed 2020-06-25(b)

Bankruptcy courts are authorized by statute to “hear and determine . . . core proceedings,” which include “allowance or disallowance of claims against the estate.” 28 U.S.C. § 157(b). ... Consequently, the Court concludes that the bankruptcy court had jurisdiction over the Proof of Claim and had the authority to issue a final order on it.
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Section 157(b)(2)(B) authorizes bankruptcy courts to adjudicate the allowance or disallowance of claims against the estate.

Vongermeten v. Planet Home Lending, LLC · filed 2021-01-05(b)(2)(B)

When Planet Home Lending, the state-court winner, filed its proof of claim in Vongermeten’s bankruptcy case it invoked this court’s statutory jurisdiction to adjudicate the “allowance or disallowance of claims against the estate”, 28 U.S.C. §157(b)(2)(B), arising in or under the Bankruptcy Code.
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Section 157(b)(2)(B) does not treat a damages proceeding as core when it falls outside the claims allowance process and the creditor’s secured claim is excluded from the plan.

PNC Bank, N.A. v. Davis · filed 2021-11-18(b)(2)(B)

This adversary proceeding did not arise in the context of the claims allowance process and, as discussed above, PNC’s secured claim against the Davises was expressly excluded by the Plan.
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Section 157 treats the allowance or disallowance of claims against a debtor’s estate as a core proceeding within the bankruptcy court’s jurisdiction.

BVS Construction v. Prosperity Bank · filed 2021-11-15(b)(2)(B)

The bankruptcy court has jurisdiction over core proceedings, which include the allowance or disallowance of claims against the debtor’s estate.
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Section 157(b)(2)(B) does not make a proceeding core under the claims allowance process when the plaintiff has not filed a proof of claim.

Rubber Flooring Systems, Inc. v. Floor-Tex Commercial Flooring, LLC · filed 2022-04-11(b)(2)(B)

Here, Plaintiff has not filed a proof of claim,31 so § 157(b)(2)(B) cannot be invoked.
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Section 157(b)(2)(B) treats the allowance or disallowance of claims against the estate as a core proceeding, including state law causes of action asserted as the basis of proofs of claim.

Porter Development Partners, LLC and PPP Management, LLC · filed 2022-05-13(b)(2)(B)

Because the claimants’ state law causes of action are asserted as the basis of their claims,8 this is a core proceeding and thus, this Court has constitutional authority to enter a final judgment.
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Section 157(b)(2)(B) treats the allowance or disallowance of claims against the estate as a core proceeding.

Porter Development Partners, LLC and PPP Management, LLC · filed 2023-01-25(b)(2)(B)

28 U.S.C. § 157 provides a non- exclusive list of matters considered core proceedings. Included in that list and relevant here is the allowance or disallowance of claims against the estate.
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Section 157(b)(2)(B) classifies the allowance or disallowance of claims as a core proceeding.

In re: Meruelo Maddux Properties, Inc. · filed 2013-04-15(b)(2)(B)

The allowance or disallowance of claims is a core proceeding under 28 U.S.C. § 157(b)(2)(B).
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Section 157(b)(2)(B) treats proceedings to allow or disallow claims against the estate as core proceedings when parties file competing proofs of claim and objections.

In Re: Vitamins Online, Inc. v. Heartwise, Inc. · filed 2024-06-20(b)(2)(B)

By doing so, they initiated a core “allowance or disallowance of claims” proceeding as contemplated by § 157(b)(2)(B).
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Section 157 treats the allowance or disallowance of a claim as a core proceeding, but that status does not require the bankruptcy court to resolve a claim objection before dismissing the case.

Edith M. Farina · filed 2025-11-24(b)(2)(B)

The Debtor correctly notes the allowance or disallowance of a claim constitutes a “core proceeding” under 28 U.S.C. § 157(b)(2). However, the dismissal of the Debtor’s case was bottomed on the Debtor’s failure to have her Bankruptcy Case in a position to confirm a plan eight months after it was filed.
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Section 157(b)(2)(B) gives bankruptcy courts authority to allow or disallow claims against the estate, including by interpreting the contracts underlying those claims.

Perryman v. Stimwave Technologies Inc. · filed 2026-03-24(b)(2)(B)

The Bankruptcy Court has both statutory and constitutional authority over the allowance or disallowance of claims against the estate. 28 U.S.C. § 157(b)(2)(B). The claims allowance process often requires the Bankruptcy Court to construe the contracts giving rise to those claims.
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Section 157(b)(2)(B) makes the allowance or disallowance of claims against the estate a core proceeding that a bankruptcy court may hear and determine.

In Re Saint Vincent's Catholic Medical Centers · filed 2011-03-14(b)(2)(B)

Adjudication of the allowance or disallowance of a claim constitutes a core proceeding within the meaning 28 U.S.C. § 157(b)(2)(B).
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Abstention in noncore proceedings

Section 157(c)(1)'s procedure for noncore proceedings does not itself justify permissive abstention.

Official Committee of Unsecured Creditors of Schlotzsky's, Inc. v. Grant Thornton, L.L.P. (In Re Schlotzsky's, Inc.) · filed 2006-08-30(c)(1)

Unless we are to read Congress’ own enactment of section 157(c)(1) of title 28 as a perverse sort of statutory self-fulfilling prophesy, that section’s operation should not factor into the abstention calculus.
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Section 157(c)(1) authorizes a bankruptcy court to hear a noncore proceeding related to a bankruptcy case and submit proposed findings and conclusions to the district court.

In Re Evergreen Security, Ltd. · filed 2007-07-17(c)(1)

This Court is authorized to hear the Fees Motion and submit proposed findings of fact and conclusions of law to the District Court pursuant to 28 U.S.C. Section 157(c)(1).
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Section 157(c)(1) limits a bankruptcy court hearing a noncore, related proceeding to proposed findings and conclusions for the district court to consider before entering judgment.

In Re Ual Corp. · filed 2008-05-31(c)(1)

Thus, as to United's claim for breach of contract, this court may not issue a final judgment, but rather is limited to making proposed findings of fact and conclusions of law, subject to entry of judgment by the district court, pursuant to 28 U.S.C. § 157(c)(1).
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Section 157(c)(1) requires a bankruptcy judge to submit proposed findings and conclusions on noncore claims when the parties do not consent to a final judgment by the bankruptcy court.

Humes v. LVNV Funding, L.L.C. (In re Humes) · filed 2013-07-17(c)(1)

The Defendants have not consented to the bankruptcy court’s entry of a final judgment on these noncore claims, and the Court will submit proposed findings of fact and conclusions of law on claims one through five in accordance with 28 U.S.C. § 157(c)(1).
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Section 157(c)(1) requires a bankruptcy court hearing a noncore claim without consent to submit proposed findings and conclusions to the district court for final judgment.

Carroll v. Robert F. Craig P.C. (In re Innovative Communication Corp.) · filed 2014-03-19(c)(1)

Therefore, while the Court has jurisdiction to hear the adversary proceedings, it may not enter a final judgment on the merits absent consent but must, instead, present proposed findings of fact and conclusions of law to the district court which will enter any final judgment.
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In noncore related proceedings under § 157(c), the court of appeals reviews the district court’s de novo examination for clear error.

Hoffman v. Lloyd · filed 2015-02-03(c)

We review for clear error the district court’s de novo examination of ... noncore related proceedings under 28 U.S.C. § 157(c).
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Section 157(c)(1) permits a bankruptcy court to hear a noncore claim without the parties’ consent to a final judgment, but requires it to submit proposed findings and conclusions to the district court for a final order.

Philadelphia Entertainment & Development Partners, L.P. v. Pennsylvania Department of Revenue (In re Philadelphia Entert · filed 2016-04-08(c)(1)

Because the Commonwealth Parties have yet to consent to the entry of a final judgment, this Court may hear the State Law Claims and then submit proposed findings of facts and conclusions of law to district court for final order.
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Section 157(c)(1) does not require a bankruptcy court to send a related proceeding's remand decision to the district court as recommended findings.

Global International Airways Corp. v. Pan American World Airways, Inc. (In re Global International Airways Corp.) · filed 1986-10-09(c)(1)

There is no reason for the bankruptcy court not to exercise the removal power in such an action as this, in which abstention may not be within the discretion of the district court, but rather may be mandatory.
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Section 157(c)(1) allows a bankruptcy judge to hear a related, noncore proceeding and submit proposed findings and conclusions to the district court for review.

Siragusa v. Collazo · filed 2020-02-20(c)(1)

“A bankruptcy judge may hear a proceeding that is not a core proceeding but that is otherwise related to” a bankruptcy case. 28 U.S.C. § 157(c)(1). In such a proceeding, the bankruptcy judge will issue proposed findings of fact and conclusions of law to the district court for its review. Id.
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Section 157(c)(1) limits a bankruptcy court in a noncore proceeding without all parties’ consent to submitting proposed findings and conclusions to the district court.

Lowe v. Gammon · filed 2021-06-09(c)(1)

Because this malpractice suit is not a “core” proceeding as described in 28 U.S.C. § 157 (b)(2), and because not all parties here were willing to consent to the entry of a final judgment by this Court, this Court is limited to providing these Proposed Findings and Conclusions to the District Court.
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Section 157(c)(1) directs a bankruptcy judge to submit proposed findings and conclusions to the district court when the requested relief is a noncore proceeding on which the judge cannot issue a final ruling.

Hegedus v. US Bank National Association, not in its individua · filed 2023-02-15(c)(1)

As this request does not fall within the categories of core proceedings on which this Court may issue a final ruling, the Court will submit proposed findings of fact and conclusions of law to the United States District Court for the Western District of Virginia pursuant to 28 U.S.C. § 157(c)(1) for consideration of the prefiling injunction.
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Section 157 requires a bankruptcy court to submit proposed findings and conclusions on noncore claims to the district court for review.

Chen v. King County Sheriff's Office · filed 2022-10-11(c)(1)

Judge Vaughan notes that Mr. Chen’s § 1983 and state law claims fall outside 28 U.S.C. § 157(b)(2)(A)’s enumerated list of core proceedings, do not stem from Plaintiff’s bankruptcy, and would not necessarily be resolved in the ... claims allowance process. Thus, the Bankruptcy Court lacks authority to enter a decision on the merits of Plaintiff’s claims and would need to submit its proposed ... findings of fact and conclusions of law to the district court for review. 28 U.S.C. § 157(c)(1). As a result, a referral of this case to the Bankruptcy Court would result in a duplication of judicial resources. ... (1) Judge Vaughan’s Report and Recommendation is ADOPTED.
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Section 157(c)(1) permits a bankruptcy court to hear a related noncore claim and submit proposed findings and conclusions for de novo review by the district court.

THE OFFICIAL COMMITTEE OF UNSECURED CREDITORS OF T v. Ace Gallery New York Corporation, a California cor · filed 2022-12-09(c)(1)

The United States Bankruptcy Court, however, does have jurisdiction to hear Pettibon’s complaint in intervention and Chrismas’s counterclaims relating to the Pettibon Drawings, which are noncore claims under its “related to” jurisdiction pursuant to 28 U.S.C. § 1334(b) and issue proposed findings of fact and conclusions of law for de novo review by the United States District Court.
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Section 157(c)(1) requires a bankruptcy court to submit proposed findings and conclusions to the district court in a noncore proceeding related to a bankruptcy case.

Insys Liquidation Trust v. Kapoor · filed 2024-07-31(c)(1)

Once a bankruptcy court determines that a pending matter is not a core proceeding under 28 U.S.C. § 157(b)(2) but is nonetheless related to a case under title 11, the court shall submit proposed findings of fact and conclusions of law to the district court. See 28 U.S.C. § 157(c)(1).
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Section 157(c)(1) requires a bankruptcy judge hearing a noncore proceeding related to a bankruptcy case to submit proposed findings and conclusions to the district court for a final decision.

The Cadle Company II, Inc. v. Crescent Bank & Trust · filed 2025-03-31(c)(1)

These claims, however, are subject to the procedure for litigating non-core “related to” matters under § 157. ... Accordingly, the Court’s decision on that claim represents this Court’s proposed ... findings of fact and conclusions of law for the district court’s consideration and issuance of a final decision.
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Section 157(c)(1) requires a bankruptcy judge in a noncore proceeding without the parties’ consent to submit proposed findings and conclusions for the district court’s final judgment.

In re Cedric Lavon Billups, Sr. and Donna Marie Billups · filed 2025-11-17(c)(1)

Therefore, because the Defendants have not consented to the Bankruptcy Court’s entry of a final judgment on any of the causes of action asserted,23 the Bankruptcy Court must submit proposed findings of fact and conclusions of law to the District Court, with the District Court to thereafter consider entry of a final judgment upon consideration of such proposed findings and conclusions and a de novo review of any matters to which a party timely objects.
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Referral of supplemental claims

Section 157(a) permits referral to a bankruptcy judge of a supplemental claim tied to a core bankruptcy proceeding, even if the claim would have no conceivable effect on the bankruptcy estate.

Hospitality Ventures/LaVista v. Heartwood 11, L.L.C. (In Re Hospitality Ventures/LaVista) · filed 2007-01-04(a)

For either of these reasons, § 157(a) authorizes referral of a core-related supplemental claim, such as the third-party claim here, even if its resolution would not have a conceivable effect on the debtor’s bankruptcy estate.
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Section 157(a) authorizes referral to a bankruptcy judge of a supplemental claim linked to a primary Bankruptcy Code claim within the district court’s jurisdiction.

Cooper v. BB Syndication Services, Inc. (In Re 222 South Caldwell Street, Ltd. Partnership) · filed 2009-06-22(a)

Referral of all bankruptcy matters to the bankruptcy judges extends to a claim lacking an independent jurisdictional basis but which has a nexus with a primary claim arising under the Bankruptcy Code within the district court’s jurisdiction. ... Therefore, § 157 authorizes this Court to hear the Trustee’s claim.
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Bankruptcy court authority to waive creditor filing fees

Under the law in effect on July 18, 2005, § 157(b)(1) allowed a bankruptcy judge hearing a referred core proceeding to decide a creditor’s request to proceed without prepaying an adversary proceeding filing fee.

Richmond, Linda Prue v. Countryman, Deborah · filed 2007-09-20(b)(1)

This result is consistent with the authority contemplated in the Code, as it states that bankruptcy courts may enter “appropriate orders and judgments,” see 28 U.S.C. § 157(b)(1), during the resolution of a title 11 proceeding. The resolution of a creditor’s motion to proceed without prepayment of a filing fee, we conclude, is consistent with the bankruptcy court’s authority to administer cases and to enter the orders necessary to allow it to do so.
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Claims against estate professionals

Section 157(b) treats a suit against an estate professional as a core proceeding when the suit arises from work critical to a Chapter 11 reorganization.

McClelland v. Grubb & Ellis Consulting Services Co. (In Re McClelland) · filed 2007-10-26(b)

Where the lawsuit arises from work performed by the estate professional that was a critical component of the Chapter 11 reorganization, the suit against that professional constitutes a core proceeding under 28 U.S.C. § 157(b).
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Section 157 treats a claim against a debtor’s attorney for malpractice in the bankruptcy proceeding as core if the claim could arise only in that context.

Galloway v. Bond, Botes & Stover, P.C. · filed 2008-10-27(b)(1)

However, even in cases where the debtor’s attorney is not court-appointed, the courts have consistently held that a claim against him for alleged malpractice in the bankruptcy proceeding will be found to be a core proceeding based on the “arising in” standard if the claim could have arisen only in the context of a bankruptcy case. ... Galloway’s malpractice claim against defendants falls well within this standard.
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Section 157(b)(1) treats a debtor’s malpractice action against professionals retained in its bankruptcy case as a core proceeding.

Epixtar Corp. v. McClain & Co. (In Re Epixtar Corp.) · filed 2009-05-05(b)(1)

For the reasons stated above, a malpractice action by the debtor against its professionals is a core proceeding.
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Section 157(b)(2)(B) covers counterclaims that determine the validity of a claim against the bankruptcy estate.

Holber v. Suffolk Construction Co. (In re Red Rock Services Co.) · filed 2014-12-08(b)(2)(B)

In fact, as Subcontractor notes, its counterclaims are more properly based on § 157(b)(2)(B), concerning "allowance or dis-allowance of claims against the estate or exemptions from property of the estate,” than on § 157(b)(2)(C), which was the provision at issue in Stem.
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Core proceedings under chapter 15

Section 157(b)(2)(P) treats foreign avoidance claims pursued in a chapter 15 case as core proceedings when they directly serve the bankruptcy court’s ancillary function.

Fairfield Sentry Ltd. v. Theodoor GGC Amsterdam (In Re Fairfield Sentry Ltd.) · filed 2011-05-23(b)(2)(P)

Against this backdrop, the BVI Avoidance Claims are precisely the “other matters under chapter 15 of the Code” over which this Court retains core jurisdiction.
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Section 157(b)(2)(P)’s chapter 15 catchall fills gaps but does not authorize a bankruptcy court to act beyond its limits.

In re Bluberi Gaming Technologies, Inc. · filed 2016-09-07(b)(2)(P)

Put another way, the “other matters” catchall operates in much the same way as section 105 of the Bankruptcy Code — it helps fill in the gaps but does not allow the court to act where it clearly should not.
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Interim orders in noncore proceedings

Section 157(c)(1) allows a bankruptcy judge to enter interim orders in a noncore proceeding related to a bankruptcy case.

Reid v. Climatemp, Inc. (In re 3RC Mechanical & Contracting Services, LLC) · filed 2013-11-26(c)(1)

§ 157(c)(1) further provides that the “any final order or judgment shall be entered by the district judge,” implying that interim orders may be entered by a bankruptcy judge under authority to “hear” the proceeding.
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Authority to issue proposed findings and recommendations

Section 157(c)(1) supplies the proposed findings and conclusions procedure when a bankruptcy court lacks constitutional authority to enter final judgment on a core claim.

Hollister Construction Services, LLC · filed 2019-10-03(c)(1)

This Court continues to view these claims as sufficiently akin to the claims identified in Stern v. Marshall, 564 U.S. 462 (2011), for which this Court does not have the constitutional authority to enter final judgment notwithstanding the fact that they are core matters. As a result, the Court must submit proposed findings of fact and conclusions of law.
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Section 157(c)(1) requires a bankruptcy court to submit proposed findings and conclusions when it cannot enter final judgment on claims before it.

Karagjozi v. Greenbaum, Rowe, Smith & Davis LLP · filed 2019-10-03(c)(1)

This Court continues to view these claims as sufficiently akin to the claims identified in Stern v. Marshall, 564 U.S. 462 (2011), for which this Court does not have the constitutional authority to enter final judgment notwithstanding the fact that they are core matters. As a result, the Court must submit proposed findings of fact and conclusions of law.
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Section 157(c)(1) permits a bankruptcy court to enter a nonfinal ruling rather than submit proposed findings of fact and conclusions of law.

Segner v. Ruthven Oil & Gas, LLC (In re Provident Royalties, LLC) · filed 2017-06-03(c)(1)

Because the determinations made in this ruling will not result in a judgment or a final order, this Court believes it may enter a ruling as opposed to proposed findings of fact and conclusions of law pursuant to 28 U.S.C. § 157(c)(1).
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Section 157(c)(1) does not permit a bankruptcy court to issue proposed findings and conclusions for claims treated as core proceedings.

Official Committee of Unsecured Creditors v. Fountainhead Group, Inc. (In re Bridgeview Aerosol, LLC) · filed 2015-09-28(c)(1)

But the parties admitted that these claims were core. Therefore, § 157(c)(1) did not permit the issuance of proposed findings and conclusions.
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Section 157 permits a bankruptcy court to issue proposed findings and recommendations even when it cannot enter final judgment on a statutorily core claim.

Blue Cross & Blue Shield v. Jemsek Clinic, P.A. · filed 2014-03-11(b)(1)

The Court agrees with other courts in this district in holding that the authority to issue findings and recommendations obtains regardless of whether the matter is deemed core or non-core under Stern analysis.
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Section 157(c)(1) permits a bankruptcy court to issue proposed findings of fact and conclusions of law in a fraudulent conveyance action treated as noncore.

Brandt v. Charter Airlines, LLC (In re Equipment Acquisition Resources, Inc.) · filed 2014-06-18(c)(1)

Because this is a fraudulent conveyance action, the Court will proceed as though it is a noncore matter within the meaning of 28 U.S.C. § 157(c)(1). Accordingly, the Court will enter proposed findings of fact and conclusions of law.
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Section 157(c)(1) requires a bankruptcy judge to issue proposed findings and conclusions for disputes over non-public rights absent party consent, with final judgment entered by the district court after de novo review.

Bank of America, N.A. v. Veluchamy (In re Veluchamy) · filed 2014-12-18(c)(1)

At least without the consent of the parties, disputes over non-public rights can only be treated by a bankruptcy judge through the issuance of proposed findings of fact and conclusions of law under 28 U.S.C. § 157(c)(1), with judgment entered by the district court after de novo review of the proposed findings and conclusions.
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Section 157 does not require a bankruptcy court to submit proposed findings and conclusions to the district court when it denies judgment on the pleadings in an interlocutory order.

Vieira v. Oleksy · filed 2022-11-02(c)(1)

In light of the denial of the motions for judgment on the pleadings, which is an interlocutory order, the Court concludes that the submission of proposed findings of fact and conclusions of law to the district court is not necessary at this stage of the proceedings.
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Section 157(c)(1) permits a bankruptcy court that lacks authority to enter final judgment to issue proposed findings of fact and conclusions of law.

In re Soundview Elite Ltd. · filed 2018-11-06(c)(1)

For the reasons discussed below, the Court answers this question in the negative and concludes that it does not have authority to issue a final judgment on the claims against Fletcher in this adversary proceeding. This decision should therefore serve as proposed findings of fact and conclusions of law pursuant to 28 U.S.C. § 157(c)(1).
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Procedure for Stern claims

Section 157(c) permits a bankruptcy court to hear a related proceeding, including a core proceeding it lacks constitutional authority to finally determine.

In re Woods · filed 2014-08-15(c)

Given that 28 U.S.C. § 157(c) permits bankruptcy courts to hear but not determine a broad range of matters based only on whether they relate to the bankruptcy case, it follows that any matter related to a case under title 11, whether or not such matter is a core proceeding, may be so heard even if the authority to hear and determine such a matter under 28 U.S.C. § 157(b)(1) is constitutionally infirm.
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Section 157(c)(1) permits a bankruptcy court to hear a Stern claim that is related to a bankruptcy case and submit proposed findings and conclusions for de novo review by the district court.

Executive Benefits Insurance Agency v. Arkison · filed 2014-06-09(c)(1)

If the claim satisfies the criteria of §157(c)(1), the bankruptcy court simply treats the claims as non-core: The bankruptcy court should hear the proceeding and submit proposed findings of fact and conclusions of law to the district court for de novo review and entry of judgment.
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Effect of transfer on applicable law

Section 157(b)(5) permits transfer of personal injury and wrongful death claims related to a bankruptcy without changing the substantive state law governing them.

Sutherland v. DCC Litigation Facility, Inc. · filed 2015-02-20(b)(5)

There is no indication that Congress intended § 157(b)(5) to be used to alter the substantive law governing the state-law cases transferred under it.
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Bankruptcy court authority over substantive consolidation

Section 157 permits a bankruptcy judge to adjudicate substantive consolidation as a core proceeding.

Bank of America, N.A. v. Cd-04, Inc. (In re Owner Management Service, LLC Trustee Corps) · filed 2015-04-29(b)(1)

Substantive consolidation was not affected by Stem and remains a core preceding that can be adjudicated by a bankruptcy judge.
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Section 157 permits a bankruptcy court to hear Stern claims and submit a report and recommendation to the district court.

Smelcer v. Citizens Bank (In re Hart Oil & Gas, Inc.) · filed 2015-07-02

Rather, the role of the bankruptcy court in such instances is to hear the claims and submit a report and recommendation to the district court.
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Jurisdiction over discharge matters

Section 157 authorizes bankruptcy courts to hear discharge matters without making a timely complaint a condition of that authority.

Johnson v. Meabon (In re Meabon) · filed 2015-08-13(b)(1), (b)(2)(I), (b)(2)(J)

Although the time limit in Kontrick is enumerated in the Bankruptcy Rules rather than the Code, the Court looked to the bankruptcy court’s authorization to hear objections to discharge pursuant to 28 U.S.C. §§ 157(b)(1) and (b)(2)(I) and (J) and noted that the grant of jurisdiction over discharge determinations “contains no timeliness condition.” Id. at 453, 124 S.Ct. 906. The distinctions between Rule versus Code limitations aside, those same statutory provisions considered by the Court in Kontrick, which lack a time prerequisite, undergird this bankruptcy court’s jurisdiction to consider Meabon’s right to a discharge in this matter.
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Section 157 helps authorize bankruptcy courts to adjudicate discharge revocation requests, and that authority is not conditioned on compliance with § 727(e)(1)’s filing deadline.

Weil v. Elliott · filed 2017-06-14

Congress granted bankruptcy courts jurisdiction to adjudicate requests for revocation of discharge in Title 28, in provisions entirely separate from the filing deadline found in Title 11. See 28 U.S.C. §§ 157, 1334(b). This jurisdictional grant is not conditioned on compliance with the time limit specified in § 727(e)(1), and indeed the two sets of provisions are not linked together in any way.
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Sovereign immunity

Section 157(b)(2) does not waive the United States’ sovereign immunity.

Brandon v. Sherwood (In re Sann) · filed 2016-02-26(b)(2)

Neither do 28 U.S.C. § 157(b)(2) or 11 U.S.C. § 330 provide for unequivocally expressed waiver of sovereign immunity by the United States.
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Core proceedings and final judgment authority

Section 157(b)(2)(A), (L), and (O) allows a bankruptcy court to enter final judgment in a qualifying core proceeding when constitutional standards are met.

Francisco Lopez and Ana Yansy Lopez · filed 2022-06-09(b)(2)(A), (L), and (O)

The Court has the authority to enter a final judgment in this contested matter because it constitutes a statutorily core proceeding pursuant to 28 U.S.C. § 157(b)(2)(A), (L), and (O), and meets all constitutional standards for the proper exercise of full judicial power by this Court.
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A fraudulent transfer action is a core proceeding under § 157(b)(2)(H) in which the bankruptcy court has statutory authority to enter a final judgment.

Milbank v. Sharpshooter II, Inc. (In re Worldwide Diamond Ventures, LP) · filed 2016-09-27(b)(2)(H)

This is a core proceeding in which this court has statuto-ry authority to issue final judgments, pur-suant to at least 28 U.S.C. § 157(b)(2)(H).
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Section 157(b)(2)(B) treats claim allowance and disallowance as core proceedings in which a bankruptcy court may enter final judgment without the parties’ consent.

Brandt v. FDIC (In re Equipment Acquisition Resources, Inc.) · filed 2016-11-21(b)(2)(B)

Thus, the Court may enter final judgment on this count with or without the parties’ consent.
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Section 157(c)(2) permits a bankruptcy court to enter final judgment in a non-core proceeding only with the parties’ consent.

Bavelis v. Doukas (In re Bavelis) · filed 2017-02-22(c)(2)

A bankruptcy court may enter: final judgment in non-core proceedings only with the consent of the parties. 28 U.S.C. § 157(c)(2).
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Section 157 directs a bankruptcy court to issue proposed findings and conclusions on non-core claims related to a bankruptcy case when it lacks authority to enter final judgment.

Brandao v. Federal National Mortgage Ass'n (In re Brandao) · filed 2017-04-07(c)(1)

However, the bulk of the claims in this proceeding-all but the turnover count under 11 U.S.C. § 542 and the fraudulent transfer count under 11 U.S.C. § 548-are not core within the meaning of 28 U.S.C. § 157(b)(1). Accordingly, the bankruptcy court does not have authority to enter final judgment on most of the counts in this matter and instead enters proposed findings and fact and conclusions of law pursuant to 28 U.S.C. § 157(c)(1).
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Section 157(c)(1) provides for a bankruptcy judge in a non-core proceeding to submit proposed findings and conclusions to the district court for entry of judgment absent the parties’ consent to final adjudication by the bankruptcy court.

Lofton v. Beneficial Financial I Inc. (In re Lofton) · filed 2017-06-05(c)(1)

Thus, absent consent, this ease would be adjudicated in accordance with 28 U.S.C. § 157(c)(1). ... Despite this matter having been determined to be non-core, the parties have consented to the entry of final orders and judgments by this Court. The Court has also considered judicial economy. I conclude that the interests of judicial economy favor the exercise of discretion to enter final orders and judgments in this matter rather than preparing and forwarding proposed findings and conclusions and judgments to the District Court.
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Section 157(c)(1) limits a bankruptcy judge in a non-core proceeding to proposing findings and conclusions for the district court’s final judgment.

Gierum v. Glick (In re Glick) · filed 2017-06-08(c)(1)

In a proceeding "related to” a case under title 11 (a "non-core” proceeding), on the other hand, a bankruptcy judge can only propose findings of fact and conclusion of law to the district court. 28 U.S.C. § 157(c)(1).
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Section 157(c)(2) permits a bankruptcy court to enter a final judgment in a non-core proceeding when all parties consent.

First Union Baptist Church of the Bronx v. TD Capital Group LLC (In re First Union Baptist Church of the Bronx) · filed 2017-08-04(c)(2)

The parties have also consented to the entry of a final decision and judgment by the Court. It is not necessary to consider whether the Court would have had the authority to enter a final judgment without that consent, as the consent provides the necessary authority. See 28 U.S.C. § 157(c)(2); Wellness Int’l Network, Ltd. v. Sharif, — U.S. -, 135 S.Ct. 1932, 1939, 1942, 1949, 191 L.Ed.2d 911 (2015).
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Section 157(c)(2) lets a bankruptcy court enter a final order in a non-core proceeding when the parties consent.

WTE-S & S Ag Enterprises, LLC v. GHD, Inc. (In re WTE-S & S Ag Enterprises, LLC) · filed 2017-08-18(c)(2)

Notwithstanding the provisions of § 157(c)(1), the Court can enter a final order in non-core proceedings with the consent of the parties. 28 U.S.C. § 157(c)(2); Wellness Int’l Network, Ltd. v. Sharif, — U.S. -, 135 S.Ct. 1932, 1939, 191 L.Ed.2d 911 (2015).
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Section 157 authorizes bankruptcy judges to hear and determine core proceedings and, with the parties’ consent, related noncore proceedings.

Parker v. Horvath (In re Horvath) · filed 2017-08-25(b)(1), (b)(2)(A), (c)(2)

As to Count I of the Plaintiff Trustee’s complaint, and the counterclaims of each of the Defendants to the extent seeking a declaration as to ownership of recipes and intellectual property, the court found it had, at the very least, “arising in” jurisdiction under § 1334(b) and that they are core proceedings under § 157(b)(1) and (2)(A) that the court may hear and determine in that each required the court to determine what property constitutes property of Horvath’s bankruptcy estate. [Id. ] at p. 9]; see also 28 U.S.C. § 1334(e)(1). And while the Defendants’ cross-claims seeking declarations that they own the property at issue were not core proceedings in that they seek judgment against the other Defendants, the court found it had “related to” jurisdiction under § 1334(b) since such determinations “could conceivably have [an] effect on the estate being administered in bankruptcy.” [Doc. # 172, p. 9 (quoting Michigan Emp’t Sec. Comm’n v. Wolverine Radio Co., Inc. (In re Wolverine Radio Co., Inc.), 930 F.2d 1132, 1142 (6th Cir. 1991) ]. The court further found that under § 157(c)(2), it had authority to hear and determine those claims since each defendant asked the court to enter judgment on their cross-claims and thus consented to such authority. [Id.] The court thus concluded that it had both jurisdiction and constitutional authority to enter final judgment with respect to the parties’ competing claims of ownership of the recipes and intellectual property at issue in this proceeding.
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Section 157 permits referral of bankruptcy matters to bankruptcy judges and allows them to enter final judgment in core proceedings.

Chatz v. Alice Rhoads Living Trust (In re Rhoads) · filed 2017-09-08(a), (b)(1), (b)(2)(A), (N), and (O)

A bankruptcy judge to whom a case has been referred may enter final judgment on any proceeding arising under the Bankruptcy Code or arising in a case under the Bankruptcy Code. 28 U.S.C. § 157(b)(1). An adversary proceeding to sell bankruptcy estate property is a core proceeding pursuant to 28 U.S.C. §§ 157(b)(2)(A), (N) and (O).
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Section 157 permits a bankruptcy court to enter a final judgment in a core proceeding when the parties consent to the bankruptcy court's authority.

Reinbold v. Morton Community Bank (In re Mid-Illini Hardwoods, LLC) · filed 2017-10-19(b)(2)(H)

It is not necessary for this Court to decide this unresolved question today, since the Trustee’s conduct in this litigation constitutes an implied waiver of her right, if she has such a right, not to consent to this Court’s authority to issue a final judgment in this proceeding. See Roell and Pringle, supra. With MCB’s express consent, this Court has the authority to enter a final judgment.
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Section 157(b)(2)(I) treats proceedings to determine the dischargeability of particular debts as core proceedings, and the Stern limitation does not bar the bankruptcy court from entering a final judgment in such a proceeding.

Trustmark Nat'l Bank v. Tegeler (In re Tegeler) · filed 2018-06-08(b)(2)(I)

Accordingly, this Court concludes that the narrow limitation imposed by Stern does not prohibit this Court from entering a final judgment here.
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Section 157 permits a bankruptcy court to enter final judgment on an easement dispute integral to determining the extent of a secured creditor’s claim.

JPMCC 2007-CIBC 19 East Greenway, LLC v. Bataa/Kierland LLC (In re Bataa/Kierland LLC) · filed 2013-07-22(b)(2)(A)

This court finds that the Bankruptcy Court had jurisdiction to enter a final judgment on the question of the scope of Debtor’s rights under the easement.
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Section 157 permits a bankruptcy court to enter final judgment in a non-core proceeding when the parties consent.

Golden v. JP Morgan Chase Bankt (In re Golden) · filed 2019-01-31(c)(2)

In addition, this Court may adjudicate these claims to final judgment to the extent that they are core proceedings pursuant to Judiciary Code Section 157(b), and to the extent that they are not core proceedings, pursuant to Judiciary Code Section 157(c) because the parties have stated their consent to this Court entering a final judgment.
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Section 157(b)(1) permits a bankruptcy court to hear and determine a motion to enforce an injunction in an order confirming a liquidating chapter 11 plan.

In re Kimball Hill, Inc. · filed 2019-01-03(b)(1)

In sum, the court has jurisdiction and statutory authority to hear and determine the Motion as it is a request to enforce an injunction extant in an order confirming a liquidating chapter 11 plan.
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Section 157(c)(2) permits a bankruptcy judge to enter final judgment in a non-core, related-to proceeding when the parties expressly consent.

Atigeo LLC v. Samson (In re Blixseth) · filed 2019-02-27(c)(2)

While the matter is a non-core, "related to" proceeding, the parties have expressly consented to entry of a final judgment by this Court.
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Section 157(c)(2) permits a bankruptcy court to enter final judgment in a non-core proceeding when the parties consent.

Rowena V. Wagner · filed 2020-04-09(c)(2)

In any event, even if the matter is deemed non-core, the Parties appear to have nonetheless consented to the entry of a final judgment by this Court as authorized by 11 U.S.C. §157(c)(2). Id. The Court therefore finds that it has the jurisdiction to enter a final judgment in this matter.
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Section 157(b)(2)(B) and (K) classify proceedings concerning claims and liens as core proceedings in which a bankruptcy court may enter final judgment.

Birch Wood Inc. v. Northborough Capital Partners, LLC · filed 2020-04-24(b)(2)(B), (K)

This a core proceeding arising under Title 11 of the United States Code as defined in 28 U.S.C. § 157(b)(2)(B) and (K), and thus this Court has constitutional authority to enter a final judgment.
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Section 157(b)(1) permits a bankruptcy court to enter final judgment in a core proceeding.

Lowe v. American Student Financial Group, Inc. · filed 2020-06-23(b)(1)

The Court has authority to enter a final judgment under § 157(b)(1) and the parties consented to entry of a final judgment by the bankruptcy court.
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Section 157(b)(1) authorizes a bankruptcy judge to decide a referred proceeding arising under the Bankruptcy Code, including a motion to dismiss a nondischargeability claim.

Handler v. Moore · filed 2020-09-02(b)(1)

A bankruptcy judge to whom a case has been referred has statutory authority to enter final judgment on any proceeding arising under the Bankruptcy Code or arising in a case under the Bankruptcy Code. 28 U.S.C. § 157(b)(1). ... The sole count of the Complaint is based on section 523(a)(2)(A) of the Bankruptcy Code. Section 523 is unequivocally a bankruptcy cause of action. ... Accordingly, determination of the Motion is within the scope of the court’s jurisdiction and statutory and constitutional authority.
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Section 157(b) authorizes a bankruptcy court to decide a core adversary proceeding even after the bankruptcy case ends.

Quinteros v. Capital Ventures International LLC · filed 2020-09-29(b)

Although the obligations under the Note are no longer being dealt with by a Chapter 13 plan, and enforcement of the Note will no longer have an effect on the administration of the estate, the court's subject matter jurisdiction is tested as of the filing of the adversary proceeding, and subject matter jurisdiction plainly existed under 28 U.S.C. § 1334(b) and was a core matter under 28 U.S.C. § 157(b) that this court is authorized to decide. Thus, even though the bankruptcy case is at an end, the court may continue to hear and decide the proceeding.
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Section 157(b)(1) gives a bankruptcy judge authority to enter final judgment in a referred proceeding arising under the Bankruptcy Code or in a bankruptcy case.

Kimball Hill, Inc. · filed 2020-09-30(b)(1)

A bankruptcy judge to whom a case has been referred has statutory authority to enter final judgment on any proceeding arising under the Bankruptcy Code or arising in a case under the Bankruptcy Code. 28 U.S.C. § 157(b)(1). ... Accordingly, the court has the jurisdiction, statutory authority and constitutional authority to hear and determine the Motion, both generally and in light of procedural posture of this matter.
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Section 157(c)(2) permits a bankruptcy court to enter final judgment in a non-core proceeding when the parties consent, including through conduct that implies consent.

Cella III, LLC v. Jefferson Parish Hospital Service District No. 2 P · filed 2020-12-29(c)(2)

Based on EJGH’s conduct in this proceeding, the Court concludes that EJGH impliedly consented to the entry of a final judgment by this Court. ... Therefore, this Court has jurisdiction to grant the relief provided for herein on a final basis pursuant to 28 U.S.C. §§ 1334 and 157(c)(2).
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Section 157(c)(2) permits a bankruptcy court to enter final judgment in a non-core proceeding when the parties consent, including through their conduct in the litigation.

Lindsey v. Duckworth Development II, LLC · filed 2021-03-25(c)(2)

In a non-core proceeding, the parties may consent to have a bankruptcy court “enter appropriate orders and judgments.” 28 U.S.C. § 157(c)(2). ... On this record, the bankruptcy court didn’t err by finding that Lindsey consented to its entry of final judgment.
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Section 157(c)(2) permits a bankruptcy court to enter final judgment in a non-core proceeding when all parties consent, including by implied consent.

Cross Keys Bank v. Ward · filed 2021-06-02(c)(2)

A bankruptcy court may hear, determine, and enter final orders and judgment on non-core matters with the consent of all parties to the proceeding. 28 U.S.C. § 157(c)(2); Wellness Int'l Network, Ltd. v. Sharif, 135 S. Ct. 1932, 1948 (2015). Implied consent will suffice.
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Section 157(b) permits a bankruptcy court to enter a final order in a core proceeding, including an eviction proceeding based on a confirmed plan and federal bankruptcy law.

Ultimate Opportunities, LLC v. The Plan Administrator · filed 2021-09-28(b)

Accordingly, it was a core proceeding in which the Bankruptcy Court could issue final orders and judgments.
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Section 157(c)(2) permits a bankruptcy court to enter final judgment in a non-core matter when the parties knowingly and voluntarily consent, including through their conduct.

McChristian v. Ditech Holding Corporation Mortgage, LLC · filed 2021-11-09(c)(2)

The Court cannot enter a final judgment in non-core matters without the parties’ consent. ... Both parties consented to this Court’s entry of a final judgment resolving the Motion.
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Section 157(c)(2) permits a bankruptcy judge to enter a final judgment in a non-core proceeding when all parties consent.

Blanchard v. Gulf Coast Premium Seafoods, LLC · filed 2021-11-19(c)(2)

Here, the parties consented to the Court entering a final judgment on non-core claims. [ECF Doc. 17]. Therefore, this Court has jurisdiction to grant the relief provided for herein on a final basis pursuant to 28 U.S.C. §§ 1334 and 157(c)(2).
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Section 157(b) permits bankruptcy courts to enter final judgments in core proceedings.

Cournoyer v. Elansari · filed 2022-04-22(b)

This is a core proceeding under 28 U.S.C. § 157(b), in which this Court has statutory authority to enter final judgments.
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Section 157 treats discharge and dischargeability disputes as core proceedings in which a bankruptcy court may enter final judgment.

Toxpro Laboratories, LLC v. Rosenburg · filed 2022-09-06(b)(2)

This proceeding is a core proceeding over which the Court has statutory and constitutional authority to enter final orders and judgments pursuant to 28 U.S.C. § 157(b)(2)(A), (I), (J), and (O).
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Section 157(b)(2) authorizes a bankruptcy court to enter final judgment in a statutorily core proceeding when constitutional standards are met.

Nationwide Judgment Recovery, Inc. v. Sorrells · filed 2022-09-27(b)(2)

The Court has the authority to enter a final judgment in this adversary proceeding because it constitutes a statutorily core proceeding pursuant to 28 U.S.C. § 157(b)(2)(A), (I), and (J), and meets all constitutional standards for the proper exercise of full judicial power by this Court.
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Notes 6001–6150 of 6,735, oldest cases first.

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