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 and non-core proceedings

Section 157(b)(2)(J) treats objections to discharge as core proceedings that a bankruptcy judge may determine by final order.

da Silva v. Jackson (In re Jackson) · filed 2017-11-15(b)(2)(J)

This is a core proceeding pursuant to 28 U.S.C. § 157(b)(2)(J) which may be determined by final order.
Read the full opinion on CourtListener →

Section 157 permits a bankruptcy judge to hear and determine a core proceeding involving a fee lien arising from a bankruptcy matter.

Sundquist v. Bank of America, N.A. (In re Sundquist) · filed 2017-11-15(b)

This is a core proceeding that a bankruptcy judge may hear and determine.
Read the full opinion on CourtListener →

Section 157(b)(2)(I) treats a proceeding to determine whether a debt is dischargeable as a core bankruptcy proceeding.

Hiner v. Koukhtiev (In re Koukhtiev) · filed 2017-11-17(b)(2)(I)

This suit is a core proceeding because it is a suit to determine the dischargeability of a specific debt pursuant to 28 U.S.C. § 157(b)(2)(I), and this suit is also core under the general “catch-all” language because such a suit is the type of proceeding that can only arise in the context of a bankruptcy case.
Read the full opinion on CourtListener →

Section 157(b)(2)(E) treats a turnover proceeding as core, allowing the bankruptcy court to enter a final order.

In re Dodart · filed 2017-11-20(b)(2)(E)

This is a core proceeding within the meaning of 28 U.S.C. § 157(b)(2)(E) and this Court may enter a final order.
Read the full opinion on CourtListener →

Section 157(b)(2)(J) treats objections to discharge as core bankruptcy proceedings.

SE Property Holdings, LLC v. Stewart (In re Stewart) · filed 2017-11-22(b)(2)(J)

SEPH’s Complaint seeks to deny the Defendants’ discharge, making this a core proceeding under 28 U.S.C. § 157(b)(2)(J).
Read the full opinion on CourtListener →

Section 157(b)(2)(I) treats determinations about the dischargeability of particular debts as core bankruptcy proceedings.

Liberty Mutual Insurance Co. v. Ward (In re Ward) · filed 2017-11-29(b)(2)(I)

This is a core proceeding under 28 U.S.C. § 157(b)(2)(I) (determinations as to the dischargeability of particular debts).
Read the full opinion on CourtListener →

Section 157(b)(2)(A) and (G) identifies estate-administration matters and motions concerning the automatic stay as core proceedings.

In re Passage Midland Meadows Operations, LLC · filed 2017-12-01(b)(2)(A), (G)

This is a core proceeding pursuant to 28 U.S.C. § 157(b)(2)(A) & (G).
Read the full opinion on CourtListener →

Section 157(b)(2) classifies proceedings concerning administration of the bankruptcy estate as core matters.

Wright v. Csabi (In re Wright) · filed 2017-12-01(b)(2)

This is a core matter as it “concern[s] the administration of the estate.” § 157(b)(2); see also In Re Southmark Corp., 163 F.3d 925, 930 (5th Cir. 1999).
Read the full opinion on CourtListener →

Section 157(b)(2) treats this preference avoidance adversary proceeding as a core bankruptcy proceeding.

Stanziale v. Sprint Corp. (In re Simplexity, LLC) · filed 2017-12-05(b)(2)

This adversary proceeding is a “core” proceeding under 28 U.S.C. § 157(b)(2)(A), (B) and (F).
Read the full opinion on CourtListener →

Section 157(b) treats a request to dismiss a bankruptcy case as a core proceeding.

In re Lopez Llanos · filed 2017-12-14(b)

This is a core proceeding pursuant to 28 U.S.C. § 157(b)(1) and (2). ... A request for dismissal is a core proceeding.
Read the full opinion on CourtListener →

Section 157(b)(2)(O) does not make an ordinary breach of contract claim a core proceeding.

Trustees of Conneaut Lake Park, Inc. v. Park Restoration, LLC (In re Trustees of Conneaut Lake Park, Inc.) · filed 2017-12-15(b)(2)(O)

However, garden variety breach of contract claims are not core proceedings.
Read the full opinion on CourtListener →

Section 157(b)(2)(L) permits a bankruptcy court to decide a disputed support-payment amount when confirming a Chapter 13 plan.

Gorman v. Ricardo Cantu, Jr. · filed 2017-12-18(b)(2)(L)

The Trustee contends that the court “lacked authority” to undertake the inquiry at all, arguing, inter alia, that the dispute is not a “core proceeding” arising from the Debtor’s bankruptcy case and that the court’s holding violates the Constitution’s Full Faith and Credit Clause. See Appellant’s Br. at 21–24. We find those arguments to be without merit.
Read the full opinion on CourtListener →

Section 157(b)(2)(N) treats a proposed sale of estate property as a core proceeding.

In re 9 Houston LLC · filed 2017-12-20(b)(2)(N)

Further, it is a core proceeding pursuant to 28 U.S.C. § 157(b)(2)(N) because it involves a proposed sale of property of the estate—i.e., the Property.
Read the full opinion on CourtListener →

Section 157(b)(2) treats motions for sanctions for violations of the automatic stay and discharge injunction as core proceedings in which a bankruptcy court may enter a final order.

In re Passa · filed 2017-12-20(b)(2)

This is a core proceeding within the meaning of 28 U.S.C. § 157(b)(2) and this Court may enter a final order.
Read the full opinion on CourtListener →

Section 157(b) treats proceedings concerning the automatic stay and orders approving property sales as core proceedings that bankruptcy judges may decide.

Heaney v. Lamento (In re Whiz Kids Development, LLC) · filed 2017-11-17(b)(2)(G) and (N)

The dispute in Counts I and II could have arisen only in the context of a bankruptcy case and would have no existence outside of the Debtor’s bankruptcy case. The Court rules that Count I of the Complaint is a core proceeding “arising under” title 11 and that Count II is a core proceeding “arising in” a case under title 11. See 28 U.S.C. § 157(b)(2)(G) and (N).
Read the full opinion on CourtListener →

Section 157(b) does not make claims arising under independent federal and state laws core proceedings merely because they are brought in a bankruptcy case.

Griffin v. Country Credit, LLC (In re Griffin) · filed 2018-03-09(b)

Accordingly, the Court finds that the Adversary is a non-core proceeding, and the Court does not have discretion to refuse to compel arbitration.
Read the full opinion on CourtListener →

Section 157(b)'s core proceeding distinction leaves a bankruptcy court without discretion to refuse arbitration of a non-core matter.

Cain v. United Credit Corp of Brookhaven (In re Cain) · filed 2018-04-12(b)

Finally, the Adversary is a non-core proceeding, and the Court does not have discretion to refuse to compel arbitration.
Read the full opinion on CourtListener →

Section 157 covers related-to proceedings involving prepetition state-law claims and permits their classification as non-core.

Mukamal v. Nat'l Christian Charitable Found., Inc. (In re Palm Beach Fin. Partners, L.P.) · filed 2018-04-20(a)

All of the claims presented in this adversary proceeding are "related to" matters within the meaning of 28 U.S.C. §§ 157(a) and 1334(b). This adversary proceeding is a non-core matter in its entirety.
Read the full opinion on CourtListener →

Section 157(b)(2) treats an action to collect accounts receivable from a prepetition transaction as non-core.

Beskrone v. Int'l Educ. Corp. (In re Pennysaver USA Publ'g, LLC) · filed 2018-07-02(b)(2)

While the Complaint states that the Adversary Proceeding is a "core" proceeding under 28 U.S.C. § 157(b)(2), both parties now reject this position. ... The Court agrees. "A proceeding to collect accounts receivable in which the underlying transaction occurred prepetition is only 'related to a case under title 11' and is, therefore, non-core."
Read the full opinion on CourtListener →

Section 157 treats declaratory claims concerning private insurance contract rights as non-core when the claims are not created by Title 11.

Ohio Security Insurance Company v. Affinitylifestyles.com, Inc. · filed 2023-07-25(b)(2)

Here, the Court agrees with Plaintiffs that their claims are non-core. At bottom, Plaintiffs’ declaratory relief claims involve state law determinations of private contractual rights, and as a result, are not created by Title 11.
Read the full opinion on CourtListener →

In a non-core proceeding, a bankruptcy judge may only issue a report and recommendation absent the parties’ consent to a final judgment.

Engelhart, Chapter 7 Trustee v. Doctors Hospital 1997, L.P. · filed 2023-08-04(c)(1)

While bankruptcy judges can issue final orders and judgments for core proceedings, absent consent, they can only issue reports and recommendations on non-core matters.
Read the full opinion on CourtListener →

Section 157 permits the bankruptcy court to hear a proposed declaratory judgment claim concerning indemnification provisions already at issue in an avoidance proceeding before it.

Quorum Health Corporation · filed 2023-08-30

This Court has jurisdiction over this matter, pursuant to 28 U.S.C. §§ 157 and 1334. ... Specifically, CHS argues that the declaratory judgment, sought by Quorum and pertaining to the indemnification agreement, is neither core, nor a non-core proceeding and is thus outside of this Court’s purview. This Court disagrees. The Trustee seeks to avoid the indemnification provisions in the underlying Adversary Proceeding — a matter which the Court has already concluded it has subject matter jurisdiction to preside over. The Motion to Intervene and the related Intervenor Complaint requesting declaratory judgment seeks an answer to that very same issue.
Read the full opinion on CourtListener →

Section 157(c)(1) prevents a bankruptcy judge from entering final judgment on non-core claims without consent but permits pretrial proceedings, including an interlocutory order dismissing some claims.

David J. Doyaga, Sr., Solely as Chapter 7 Trustee v. Fitoussi · filed 2023-09-03(c)(1)

Absent consent, a bankruptcy judge may not enter a final judgment in non-core matters. See 28 U.S.C. § 157(c)(1). A bankruptcy court, however, may handle all pretrial proceedings, including entering an interlocutory order dismissing some, but not all, non-core causes of action in an adversary complaint.
Read the full opinion on CourtListener →

Section 157(b) treats a state-law single business enterprise claim against a noncreditor as non-core, even when it seeks recovery tied to a preference action.

Luxe Spaces, LLC v. Quick Funding Group LLC · filed 2023-09-06(b)

As a result, the case against Panthers is “non-core” under 28 U.S.C. § 157(b).
Read the full opinion on CourtListener →

Section 157(b)(2) can classify fraudulent transfer and related recovery claims as core proceedings even when the bankruptcy court treats them as non-core for adjudication.

Menotte v. Keough · filed 2023-09-14(b)(2)

Counts VI and VII are core matters under 28 U.S.C. § 157(b)(2)(A), (H), and (O) that nonetheless should be treated as non-core matters to facilitate the efficient resolution of this Adversary Proceeding.
Read the full opinion on CourtListener →

Prepetition state law claims may be non-core proceedings even when their outcome could affect a pending bankruptcy case.

Wythe Berry Fee Owner LLC - Adversary Proceeding · filed 2023-10-05

It involves prepetition state law claims that are undoubtedly non-core. The claims fall within this Court’s “related to” jurisdiction as resolution of such claims could conceivably impact the Debtor’s pending bankruptcy proceeding (Case No. 22-11340).
Read the full opinion on CourtListener →

Section 157(c) bars a bankruptcy court from entering final judgment in a non-core proceeding without the parties’ consent.

Ohai v. PNC Bank National Association, Inc. · filed 2023-10-19(c)

The bankruptcy court therefore has no jurisdiction over these claims and, even if it did have “related to” jurisdiction, as these are not core proceedings, the Court cannot enter a final judgment without the parties’ consent.
Read the full opinion on CourtListener →

Section 157(c)(1) calls for a bankruptcy court to submit proposed findings and conclusions on non-core claims to the district court for an order.

Stevenson v. William Noble Rare Jewels, LP · filed 2023-11-21(c)(1)

As to these non-core claims, therefore, this opinion states the Court’s proposed findings of facts and conclusions of law, see 28 U.S.C. § 157(c)(1), and the Court will recommend that the United States District Court for the Eastern District of Michigan enter an order thereon.
Read the full opinion on CourtListener →

Section 157 defines the bankruptcy court's jurisdiction over core and non-core proceedings.

Rothman v. Friedman Vartolo, LLP · filed 2024-02-20(b)(1), (c)(1)

This matter is not a core proceeding. Nowhere in the Complaint does the Plaintiff invoke any substantive right provided by title 11. Nor does she raise any claims which could arise only in the context of a bankruptcy case.
Read the full opinion on CourtListener →

Section 157(c)(1) requires a bankruptcy judge to submit proposed findings and conclusions to the district court when hearing a non-core proceeding related to bankruptcy.

Hegedus v. US Bank National Association · filed 2024-03-05(c)(1)

A bankruptcy judge may hear a proceeding that is not a core proceeding but that is otherwise related to bankruptcy, in which case the bankruptcy judge must issue proposed findings of fact and conclusions of law to the district court for final disposition. 28 U.S.C. § 157(¢)(1). The district court then must enter a final order “after considering the bankruptcy judge’s proposed findings and conclusions and after reviewing de novo those matters to which any party has timely and specifically objected.” Id.
Read the full opinion on CourtListener →

Section 157 treats a divorce action related to a bankruptcy case as a non-core proceeding when the action is considered separately from a relief from stay motion.

Topfer v. Topfer · filed 2024-03-25

Considering the seventh factor, the substance rather than the form of an asserted “core” proceeding, the Bankruptcy Court correctly stated that it had no core jurisdiction pertaining to the divorce action other than for the purpose of considering mandatory abstention.
Read the full opinion on CourtListener →

Section 157(c)(1) permits a bankruptcy court to hear a related non-core proceeding and submit proposed findings and conclusions for a final decision by the district court.

All Year Holdings Limited - Adversary Proceeding · filed 2024-04-03(c)(1)

Under 28 U.S.C. § 157(c)(1), the bankruptcy court may hear a non-core proceeding that is related to a case under title 11, but “the bankruptcy judge shall submit proposed findings of fact and conclusions of law to the district court, and any final order or judgment shall be entered by the district judge after considering the bankruptcy judge’s proposed findings of fact and conclusions and after reviewing de novo those matters to which any party has timely and specifically objected.” ... If a trial is required, the bankruptcy court can enter proposed findings of fact and conclusions of law.
Read the full opinion on CourtListener →

Section 157 treats claims that invoke a substantive bankruptcy right or could arise only in bankruptcy as core proceedings; ordinary state law tort claims are non-core.

Krol v. Whitten Law Office LLC · filed 2024-05-15

Another important issue to the request for equitable remand is the fact that this case is not a “core” bankruptcy proceeding under 28 U.S.C. § 157.
Read the full opinion on CourtListener →

Section 157 distinguishes core bankruptcy proceedings from non-core proceedings; the trustee’s state-law claims here are non-core.

Rescia Ch. 7 Trustee v. EK Real Estate Fund I, LLC · filed 2024-06-10(b)(2)

The non-core proceedings concern the Trustee’s state law claims.
Read the full opinion on CourtListener →

Section 157(c)(1) requires a bankruptcy court handling a non-core proceeding to submit proposed findings of fact and conclusions of law to the district court for review.

Simpson v. First Republic Bank · filed 2024-06-10(c)(1)

If a matter is a non-core—that is, if a matter merely “relate[s] to” a title 11 proceeding—a bankruptcy court must instead “submit proposed findings of fact and conclusions of law to the district court” for review. See 28 U.S.C. § 157(c)(1).
Read the full opinion on CourtListener →

Section 157(c)(1) requires a bankruptcy court handling a non-core proceeding related to a bankruptcy case to submit proposed findings and conclusions to the district court.

JJ Arch LLC · filed 2024-06-10(c)(1)

If a matter is a non-core—that is, if a matter merely “relate[s] to” a title 11 proceeding—a bankruptcy court must instead “submit proposed findings of fact and conclusions of law to the district court” for review. See 28 U.S.C. § 157(c)(1).
Read the full opinion on CourtListener →

Section 157(c)(1) allows a bankruptcy court to submit proposed findings and conclusions in a non-core proceeding for de novo review by the district court.

Nobilis Health Corp. - Adversary Proceeding · filed 2024-06-12(c)(1)

For those defendants, the Court may make (and this Memorandum Opinion shall constitute) proposed findings and conclusions of law that are subject to de novo review by the district court.
Read the full opinion on CourtListener →

Section 157(c)(1) permits a bankruptcy court to issue proposed findings and conclusions on non-core claims, subject to de novo review by the district court.

Giuliano v. Fleming · filed 2024-10-07(c)(1)

The claims for breach of fiduciary duty against the remaining defendants, however, remain non-core matters. For those defendants, the Court may make (and this MemorandumOpinionshallconstitute)proposedfindingsandconclusionsoflawthat are subject to de novo review by the district court.
Read the full opinion on CourtListener →

Section 157 treats a prepetition state law contract claim as non-core even when it is pleaded as a turnover claim.

BBCK One Holding Corp. v. West Coast Management, LLC · filed 2024-11-13

Under 28 U.S.C. § 157, bankruptcy judges are empowered to decide core proceedings, those cases arising under Title 11, proceedings arising under Title 11, and proceedings arising in a case under Title 11, including matters concerning the administration of the estate. ... As discussed above, Plaintiff’s causes of action in this case are non-core, state law causes of action, “related to” the case under Title 11. Plaintiff’s reliance on the turnover count under Section 542 of the Bankruptcy Code is not enough to convert this adversary proceeding into a core matter because the claim originates from a pre-petition contract governed by state law.
Read the full opinion on CourtListener →

Section 157(c)(1) limits a bankruptcy court in a non-core proceeding to proposed findings and conclusions for the district court’s de novo review and final decision.

Taggart v. PHH Mortgage Corp · filed 2025-02-26(c)(1)

Because Taggart’s claims against TIAA are non-core, the Bankruptcy Court lacked jurisdiction to dismiss them. ... Upon remand, the District Court shall treat the Bankruptcy Court’s discussion of TIAA’s motion to dismiss as proposed findings of fact and conclusions of law subject to the District Court’s de novo review.
Read the full opinion on CourtListener →

Section 157(c) treats a purported turnover proceeding as non-core when substantial disputes over state-law property rights remain.

MedEx, LLC v. RedMed, LLC · filed 2025-07-03(c)

Such significant disputes render MedEx’s purported turnover claim non-core.
Read the full opinion on CourtListener →

Section 157(c)(1) treats a state constitutional challenge to attorney disciplinary costs as a non-core proceeding.

Albert-Sheridan · filed 2025-10-30(c)(1)

They are non-core under 28 U.S.C. § 157(c)(1)'° and lack independent federal jurisdiction absent Albert's bankruptcy filing.
Read the full opinion on CourtListener →

Section 157(b) classifies an adversary proceeding as core or non-core based on the nature of the claim.

Stanford · filed 2026-01-16(b)

Based upon the nature of the Federal Claim, the Adversary Proceeding is non-core in nature for purposes of 28 U.S.C. § 157(b).
Read the full opinion on CourtListener →

Section 157(b) governs whether a bankruptcy proceeding is core; the court classified this proceeding as non-core.

Tapia · filed 2026-01-21(b)

This is a non-core proceeding under 28 U.S.C. § 157(b), but the parties have consented to this Court’s authority to enter final orders.
Read the full opinion on CourtListener →

Section 157(c) allows a bankruptcy court to hear related non-core proceedings and enter interlocutory orders, but limits its authority to enter final orders or judgments.

In re ACJK, Inc. · filed 2026-02-20(c)

Section 157(c) expressly authorizes bankruptcy courts to hear non-core but related proceedings and limits only the courts’ ability to enter final orders or judgment.
Read the full opinion on CourtListener →

Section 157 permits a bankruptcy court to enter final judgment in a related non-core proceeding when the parties consent.

Rofkahr · filed 2026-03-30(c)

However, in this proceeding, the parties entered into an agreed order on February 20, 2026, in which they expressly consented to this Court’s entry of a final order. (Dkt. No. 22.) Therefore, the Court may enter a final judgment in this non-core proceeding.
Read the full opinion on CourtListener →

Section 157(c)(1) treats a bankruptcy judge’s ruling in a non-core related proceeding as proposed findings and conclusions for district court review.

In Re Andrews · filed 2026-04-03(c)(1)

Count V is also subject to de novo review, though for a different reason: it is a claim under Massachusetts consumer protection law and is therefore a “non-core” or “related-to” claim. For that reason, the Bankruptcy Judge’s decision on that count does not constitute a final order engendering appellate review. See Sheridan v. Michels (In re Sheridan), 362 F.3d 96, 100 (1st Cir. 2004). Instead, the rulings below as to Count V are treated as “proposed findings of fact and conclusions of law to [this Court].” See In re Lac-Mégantic Train Derailment, 999 F.3d at 79 (citing 28 U.S.C. § 157(c)(1)).
Read the full opinion on CourtListener →

Section 157(b)(1) treats a counterclaim as non-core when deciding the creditor’s bankruptcy claim will not necessarily decide the counterclaim.

Next Science v. Pivotal Med Supply · filed 2026-04-13(b)(1)

Because it does not appear that the adjudication of Plaintiff’s bankruptcy claim (either by way of the determination of Plaintiff’s causes of action in the Adversary or Defendant’s objection to Plaintiff’s bankruptcy claim which has been consolidated with the Adversary) will necessarily determine, or require the determination of, either of the Counterclaims, the Counterclaims are non-core in nature for purposes of 28 U.S.C. § 157(b)(1), notwithstanding the provisions of 28 U.S.C. § 157(b)(2)(C).
Read the full opinion on CourtListener →

Section 157(c) governs proceedings related to a bankruptcy case that are non-core; with the parties’ consent, a bankruptcy court may enter a final judgment.

StopLoss Specialists, LLC v. Insured Advocacy Group · filed 2026-06-15(c)

This is a non-core proceeding that is related to a case under title 11. 28 U.S.C. § 157(c). The parties’ express and implied consent provides this Court constitutional authority to enter a final judgment.
Read the full opinion on CourtListener →

Section 157 generally allows bankruptcy judges to finally decide core proceedings but limits them to recommended findings and conclusions in non-core proceedings.

Hoffman v. Brown (In Re Brown) · filed 1985-12-30(b)(1), (c)(1)

Additionally, the new law distinguishes between so-called “core” and “non-core” proceedings, indicating generally that the bankruptcy judge may hear and finally determine core matters, but may only make recommended findings of fact and conclusions of law in non-core matters, which a district judge may either accept or reject. 28 U.S.C. 157(b)(1), (c)(1), (2).
Read the full opinion on CourtListener →

Section 157(c)(1) limits a bankruptcy court’s authority to enter final orders or judgments in a non-core proceeding without the parties’ consent.

Grand Traverse Development Co. v. Board of Trustees of the General Retirement System (In Re Grand Traverse Development C · filed 1993-02-08(c)(1)

We further note that both the Debtors and the GRS correctly identify the litigation removed from state court to this court as non-core containing neither bankruptcy nor any other issue founded on federal law. Further, pursuant to 28 U.S.C. § 157(c)(1) both parties have refused to consent to this court’s entry of final orders or judgments and at the same time both parties have requested a jury trial which we are instructed this court does not have the power to conduct.
Read the full opinion on CourtListener →

Section 157(c)(1) limits a bankruptcy court’s authority over non-core proceedings and provides for de novo district court review.

Foxmeyer Health Corp. v. McKesson Corp. (In Re Foxmeyer Corp.) · filed 1998-11-19(c)(1)

These claims are premised on state law causes of action and hence are non-core matters.
Read the full opinion on CourtListener →

Section 157(c) bars a bankruptcy court from entering a final judgment in a non-core proceeding without the parties’ consent.

Peterson v. Commerce Bank, N.A. (In Re Mattson) · filed 2011-03-28(c)

Because the case is not a core proceeding, but instead a related to proceeding, the Court does not have the authority to issue a final judgment in this case absent consent of the parties.
Read the full opinion on CourtListener →

Section 157 lists fraudulent conveyance proceedings as core, but the bankruptcy court cannot enter a final judgment on a state-law fraudulent transfer claim.

National Union Fire Insurance Company of Pittsburgh, PA v. DiMucci · filed 2015-04-02(b)(2)(H)

Federal precedent holds that fraudulent transfer claims are not "core" bankruptcy proceedings, and thus the federal bankruptcy court's default judgment against DiMucci LLC was not a final judgment that would bar this case under the doctrine of res judicata.
Read the full opinion on CourtListener →

Core proceedings—counterclaims by the estate

Section 157(b)(2)(C) treats counterclaims by the bankruptcy estate against persons filing claims against the estate as core proceedings.

Enslein v. Johnston · filed 2018-03-27(b)(2)(C)

The text of the statute says “counterclaim,” not “claim,” so 28 U.S.C. § 157(b)(2)(C) does not apply and abstention is mandatory.
Read the full opinion on CourtListener →

Section 157(b)(2)(C) treats an estate counterclaim against a creditor who filed a proof of claim as a core proceeding.

Davis v. State (In re Venoco, LLC) · filed 2019-01-02(b)(2)(C)

Both Penson Techs. and ResCap support the Court's finding that the adversary proceeding qualifies as a counterclaim to the Defendants' proof of claim. Therefore, the adversary proceeding is core and will almost certainly be resolved, or is resolvable, in the claim proceeding, i.e., Defendants' $ 130 million claim arising from Platform Holly and the EOF.
Read the full opinion on CourtListener →

Section 157(b)(2)(C) treats counterclaims by the estate against parties that filed claims against the estate as core proceedings; a debtor’s counterclaims against a party that filed no claim are non-core.

Credit Bureau Systems, Inc. v. Elam · filed 2019-10-10(b)(2)(C)

While “counterclaims by the estate against persons filing claims against the estate” is listed as a core proceeding at 28 U.S.C. § 157(b)(2)(C), CBS has not filed a claim in the underlying bankruptcy case and the counterclaims are not by the estate, but the debtor. Consequently, the counterclaims are non-core, and this court has no constitutional authority to enter a final judgment on debtor’s counterclaims absent consent.
Read the full opinion on CourtListener →

Section 157(b)(2)(C) treats a counterclaim by the estate against a person who filed a claim against the estate as a core matter the bankruptcy court may hear.

Alliance Shippers, Inc. v. Choez (In re Choez) · filed 2018-10-26(b)(2)(C)

This Court may hear Mr. Choez's counterclaim because it is a "counterclaim[ ] by the estate against [a] person[ ] filing [a] claim[ ] against the estate." 28 U.S.C. § 157(b)(2)(C).
Read the full opinion on CourtListener →

Section 157(b)(2)(C) does not make a suit a core counterclaim proceeding when no proof of claim remains against which a counterclaim can be asserted.

MESEARCH MEDIA TECHNOLOGIES LIMITED v. CRIVELLA HOLDINGS LIMITED · filed 2025-10-22(b)(2)(C)

Therefore, since the relief sought in the Complaint cannot be considered a counterclaim to a proof of claim, the claims set forth in the Complaint cannot fall within a “core” proceeding under § 157(b)(2)(C).
Read the full opinion on CourtListener →

Provisional transfer

Section 157(b)(5) does not expressly provide for provisional transfer of personal injury and wrongful death claims.

In re Imerys Talc Am., Inc. · filed 2019-05-09(b)(5)

J&J cites no statutory authority for provisional relief, and § 157(b) does not provide for "provisional" transfer.
Read the full opinion on CourtListener →

Core jurisdiction over fee applications

Section 157(b)(2)(A) treats fee applications as core proceedings over which a bankruptcy court retains jurisdiction after the case closes.

MBF Inspection Services, Inc. and Associated Case in US District Court · filed 2019-12-24(b)(2)(A)

In short, closing and opening cases is relevant to estate administration but not to the Court’s subject matter jurisdiction. Here, the Court does not need an open case to retain its core jurisdiction over the fee applications.
Read the full opinion on CourtListener →

Authority to determine underlying liability

Section 157 permits a bankruptcy court deciding dischargeability to determine liability on an underlying federal claim first.

Diano v. Diano · filed 2020-06-11(b)(2)(I)

At its core this is a proceeding to determine the non- dischargeability of the Plaintiffs’ claims, one of which is a claim under 18 U.S.C. § 1836 for the Defendant’s alleged misappropriation of trade secrets. Of necessity, the Court must first determine the Defendant’s liability for the claim, and then whether the nature of the claim falls within a non-discharge provision of Code § 523(a). The Motion as to this claim is denied.
Read the full opinion on CourtListener →

Effect of transfer motion on remand

A pending motion under § 157(b)(5) to fix venue does not require a court to delay remand when mandatory abstention applies.

Montross v. Our Holy Redeemer Roman Catholic Church · filed 2023-08-29(b)(5)

The Court is also unpersuaded by Defendants’ argument that holding the remand motions in abeyance pending Judge Schofield’s decision on the Diocese’s Section 157(b)(5) motion would be the “more judicially efficient approach.”
Read the full opinion on CourtListener →

A pending Section 157(b)(5) venue motion does not require a district court to delay ruling on a motion to remand.

ARK669 Doe v. Holy Trinity Diocesan High School · filed 2023-08-29(b)(5)

The Court therefore is compelled to rule on the remand motions without waiting for a decision on the Section 157(b)(5) motion.
Read the full opinion on CourtListener →

A pending motion to transfer personal injury claims under § 157(b)(5) does not prevent the district court from deciding a motion to remand.

DIETERLY v. BOY SCOUTS OF AMERICA · filed 2020-06-24(b)(5)

However, at least two recent decisions have found that a district court, exercising its role as jurisdictional gatekeeper, should decide both whether removal was proper in the first place as well as any pending motion to remand even though a nationwide motion to transfer venue pursuant to 28 U.S.C. § 157(b)(5) is pending1. ... Therefore, the Court will consider the Plaintiff’s motion to remand.
Read the full opinion on CourtListener →

A pending motion to fix venue under § 157(b)(5) does not require a court to delay ruling on remand.

ARK680 Doe v. Congregation of the Holy Spirit · filed 2023-11-09(b)(5)

Like those courts, this Court sees no reason to reserve ruling on the remand decision prior to a decision on the Section 157(b)(5) motion.
Read the full opinion on CourtListener →

A pending Section 157(b)(5) transfer motion need not delay a decision to remand a related case to state court.

Nardella v. St. Sylvester Roman Catholic Church · filed 2023-11-09(b)(5)

Like those courts, this Court sees no reason to reserve ruling on the remand decision prior to a decision on the Section 157(b)(5) motion.
Read the full opinion on CourtListener →

A pending motion to fix venue under § 157(b)(5) does not require a court to delay ruling on remand.

M. B. v. Church of St. Aidan · filed 2023-11-09(b)(5)

Like those courts, this Court sees no reason to reserve ruling on the remand decision prior to a decision on the Section 157(b)(5) motion.
Read the full opinion on CourtListener →

A pending motion to fix venue under Section 157(b)(5) does not require a court to delay ruling on remand.

Ciaravino v. St. Brigid's Catholic Church · filed 2023-11-09(b)(5)

Like those courts, this Court sees no reason to reserve ruling on the remand decision prior to a decision on the Section 157(b)(5) motion.
Read the full opinion on CourtListener →

A court need not wait for a pending motion under § 157(b)(5) to be decided before remanding cases from which it must abstain.

P.W. v. Holy Name of Mary Roman Catholic Church · filed 2023-11-09(b)(5)

Like those courts, this Court sees no reason to reserve ruling on the remand decision prior to a decision on the Section 157(b)(5) motion.
Read the full opinion on CourtListener →

A pending motion under § 157(b)(5) to fix venue does not require a court to delay ruling on a motion to remand.

Edge v. St. Martin of Tours Roman Catholic Church · filed 2023-11-09(b)(5)

Like those courts, this Court sees no reason to reserve ruling on the remand decision prior to a decision on the Section 157(b)(5) motion.
Read the full opinion on CourtListener →

Supplemental jurisdiction

Section 157(b) does not authorize a bankruptcy court to hear claims supported only by a district court’s supplemental jurisdiction under § 1367.

Herman v. Sonier · filed 2020-07-06(b)

A bankruptcy court’s authority is limited by 28 U.S.C. § 157(b) to those matters for which subject matter jurisdiction exists under 28 U.S.C. § 1334(b). That authority does not include matters for which subject matter jurisdiction might exist in the district court under the supplemental jurisdiction provisions of 28 U.S.C. § 1367.
Read the full opinion on CourtListener →

A bankruptcy court may exercise pendent jurisdiction over third-party claims accompanying a core proceeding, even when those claims may not independently be related to the bankruptcy.

Dechert Price & Rhoads v. Direct Satellite Communications, Inc. (In Re Direct Satellite Communications, Inc.) · filed 1988-06-30

We can perceive no reason why a bankruptcy court cannot exercise pendent jurisdiction and hear non-federal claims raised in a proceeding before it, in the same fashion as any other federal court.
Read the full opinion on CourtListener →

Authority to issue interlocutory orders

Section 157 permits a bankruptcy judge to issue interlocutory orders even when the judge lacks authority to enter final judgment.

MLN Company v. Clear the Air, LLC · filed 2021-06-22(c)(1)

Nevertheless, this Court may issue interlocutory orders, even in proceedings in which the Court does not have authority to issue a final judgment.
Read the full opinion on CourtListener →

Section 157(c)(1) permits a bankruptcy court to enter an interlocutory ruling directly without submitting proposed findings of fact and conclusions of law.

The Cadle Company II, Inc. v. Crescent Bank & Trust · filed 2021-10-27(c)(1)

Finally, the Court rejects Crescent’s assertion that Stern v. Marshall15 requires this Court’s rulings on the matters presently before it to be in form of proposed findings of fact and conclusions of law under 28 U.S.C. § 157(c)(1). Because the Court is not dismissing all of the Trustee’s claims against Crescent, the Court’s ruling here is interlocutory. As a result, Stern v. Marshall is not implicated, and the Court may enter its ruling on Crescent’s motions directly.
Read the full opinion on CourtListener →

Section 157 permits a bankruptcy court to deny a motion to dismiss as an interlocutory order even when the proceeding’s core status is unresolved.

Charmoli v. Aspen American Insurance Company · filed 2023-04-28(c)

Decisions disagree about whether contests over a debtor’s insurance coverage for claims against the bankruptcy estate, like this one, are core proceedings, in which this court may statutorily enter final orders without the parties’ consent, or non-core proceedings, in which it may enter only interlocutory orders, absent consent. See §157(b) & (c). ... But “denials of motions to dismiss are generally not final orders, even in the bankruptcy context.” In re Vlasek, 325 F.3d 955, 960 (7th Cir. 2003) (quoting Fruehauf Corp. v. Jartran, Inc. (In re Jartran, Inc.), 886 F.2d 859, 864 (7th Cir. 1989)). Therefore, this court’s authority to deny Aspen’s motion to dismiss is secure.
Read the full opinion on CourtListener →

Personal Injury Tort Claim

Section 157(b)(2)(B) excludes liquidation or estimation of personal injury tort claims from core proceedings, while § 157(b)(5) assigns their trial to a specified district court.

Tyler Gordon · filed 2022-11-10(b)(2)(B), (b)(5)

Thus, the Court need not adopt a definition of “personal injury tort” because even under the most restrictive definition, the Court finds that the claims alleged constitute a personal injury tort for purposes of 28 U.S.C. § 157. Because Creditor’s claims are personal injury torts, the liquidation and estimation of such claims is not a core matter. 28 U.S.C. § 157(b)(2)(B). 28 U.S.C. § 157(b)(5) provides “that personal injury tort and wrongful death claims shall be tried in the district court in which the bankruptcy case is pending, or in the district court in the district in which the claims arose, as determined by the district court in which the bankruptcy case is pending.”
Read the full opinion on CourtListener →

Bankruptcy court jurisdiction

Section 157 authorizes bankruptcy courts to hear core proceedings and enter final determinations in them.

Moyer v. Guitton-Belon · filed 2022-12-01(a), (b)(2)(I), (b)(2)(J)

The court has jurisdiction over this adversary proceeding under 28 U.S.C. §§ 1334 and 157(a). This case is statutorily core under 28 U.S.C. § 157(b)(2)(I) and (J) and is constitutionally core. The court, therefore, has authority to hear this case and make a final determination.
Read the full opinion on CourtListener →

Section 157(b)(2)(A), (L), and (O) treats this adversary proceeding concerning a confirmed plan as a core proceeding.

Benavidez-Hunt v. G.B.G. Ranch, Ltd. · filed 2022-12-04(b)(2)(A), (L), (O)

This adversary proceeding is a core proceeding under 28 U.S.C. §§ 157(b)(2)(A), (L) and (O).
Read the full opinion on CourtListener →

Section 157(b)(2) identifies categories of bankruptcy matters that are core proceedings.

Irving H. Picard, Trustee for the Liquidation of B v. Inteligo Bank Ltd · filed 2022-12-15(b)(2)(A), (F), (H) and (O)

This is a core proceeding under 28 U.S.C. § 157(b)(2)(A), (F), (H) and (O).
Read the full opinion on CourtListener →

Section 157(b)(2)(A), (B), and (O) identifies matters concerning estate administration, claim allowance, and related bankruptcy matters as core proceedings.

Jaime Omar Luera and Christina Isabel Paz · filed 2022-12-16(b)(2)(A), (B) and (O)

This court determines that pursuant to 28 U.S.C. § 157(b)(2)(A), (B) and (O) this proceeding contains core matters, as it primarily involves allowance of claims and proceedings concerning the administration of this estate. This proceeding is also core under the general “catch-all” language because such a suit is the type of proceeding that can only arise in the context of a bankruptcy case.
Read the full opinion on CourtListener →

Section 157 allocates bankruptcy jurisdiction between district and bankruptcy courts; its rules do not limit subject-matter jurisdiction.

Promise Healthcare Group, LLC · filed 2023-04-20

The rules set forth in § 157 of title 28 merely allocate the subject-matter jurisdiction granted in § 1334. The rules are not themselves jurisdictional.
Read the full opinion on CourtListener →

Section 157 authorizes district courts to refer bankruptcy matters to bankruptcy judges and grants bankruptcy judges authority over core proceedings, including motions to terminate, annul, or modify the automatic stay.

POTTER v. CUMBERLAND COUNTY SHERIFF'S DEPARTMENT · filed 2023-07-17(a), (b)(1), (b)(2)(G)

“Bankruptcy judges may hear and determine all cases under title 11 and all core proceedings arising under title 11, or arising in a case under title 11, referred under subsection (a) of this section, and may enter appropriate orders and judgments, subject to review under section 158 of this title.” § 157(b)(1). “Core proceedings” include “motions to terminate, annul, or modify the automatic stay.” § 157(b)(2)(G). The Bankruptcy Court thus had jurisdiction over this matter and its decision is affirmed.
Read the full opinion on CourtListener →

Section 157 does not require a final determination that affected property belongs to the estate before a bankruptcy court may hear estate administration matters and issue orders.

In re: Charlene Gruntz · filed 2012-10-15

There is nothing in the main bankruptcy jurisdiction statutes, 28 U.S.C. §§ 157 and 1334, stating or suggesting that bankruptcy courts lack authority to hear matters and issue orders otherwise affecting administration of the bankruptcy estate unless and until a final determination is made that property potentially impacted by the matters and orders is estate property.
Read the full opinion on CourtListener →

Section 157(a) lets a district court refer bankruptcy cases and proceedings to a bankruptcy court, whose authority is limited to exercising the district court’s jurisdiction under the conditions in § 157.

Pettine v. Lofstedt · filed 2023-11-15(a)

Section 157 only authorizes a district court, by referring cases and proceedings to a bankruptcy court, to grant authority to the bankruptcy court to exercise the jurisdiction vested in the district court under § 1334, on the conditions and subject to the limitations set forth in § 157(b) to (e).
Read the full opinion on CourtListener →

Section 157(c)(2) permits a bankruptcy court to decide a non-core proceeding when the parties consent; consent may be implied from litigating without objection.

Teter v. Baumgart · filed 2024-01-03(c)(2)

And by continuing to litigate Teter’s EAJA request without objection, the Trustee in effect consented to the bankruptcy court’s handling of the matter, making it a valid exercise of that court’s jurisdiction.
Read the full opinion on CourtListener →

Section 157 permits district courts to refer bankruptcy proceedings to bankruptcy judges and governs when bankruptcy judges may enter final orders or submit proposed findings.

Fernando A. Neiva - Adversary Proceeding · filed 2024-02-09(a), (b)(1), (c)(1), (c)(2)

28 U.S.C. § 1334(b) imbues the district court with jurisdiction over “all civil proceedings arising under title 11, or arising in or related to cases under title 11,” and 28 U.S.C. § 157(a) permits the district court to “refer any or all such proceedings to the bankruptcy judges of their district,” Stern v. Marshall, 564 U.S. 462, 473 (2011), which the District Court of Massachusetts has done, see D. Mass. Rule 201. This Court thus has jurisdiction over all matters arising under, arising in, or related to a bankruptcy case, although it may only enter final orders on those matters which are determined to be “core,” see 28 U.S.C. § 157(b)(1), and must submit proposed findings of fact and conclusions of law to the district court for any “non-core” matter, unless the parties consent to the entry of a final order by the bankruptcy court, see 28 U.S.C. § 157(c)(1), (2).
Read the full opinion on CourtListener →

Section 157(b) does not authorize a bankruptcy court to hear and determine Corporate Transparency Act violations.

Jean Michel LeTennier, Sr. · filed 2024-04-11(b)

This Court does not have jurisdiction to hear and determine cases arising under title 31. 28 U.S.C. § 1334; 28 U.S.C. § 157(b).
Read the full opinion on CourtListener →

Section 157(b)(2)(I) permits a bankruptcy court to resolve a money claim tied to dischargeability, but does not give it jurisdiction over a standalone damages claim after the dischargeability counts have been resolved.

Woolf v. Simone · filed 2024-06-20(b)(2)(I)

Commencing a new action here, however, is not possible at this stage because the Court would not have jurisdiction over a standalone Count VII, especially after final judgment has entered on Counts I through VI.11 See Surgical Capital Solutions, Inc. v. Awaisi (In re Awaisi), 627 B.R. 886 (Bankr. E.D. Mich. 2021) (“the Court’s authority and subject matter jurisdiction to enter a money judgment . . . [i]s dependent on its statutory authority, under 28 U.S.C. § 157(b)(2)(I), to determine the dischargeability Defendant–Debtor’s debt to Plaintiff”); cf. Porges v. Grunal & Co. (In re Porges), 44 F.3d 159, 164 (2d Cir. 1995) (“once a court sitting in equity has jurisdiction over the parties to a controversy brought before it, the court can decide all disputed matters and decree complete relief”).
Read the full opinion on CourtListener →

Section 157 permits a bankruptcy court to hear an individual's Title 11 case despite the individual's spouse having a concurrent bankruptcy case in another district.

In Re Philip Emiabata · filed 2024-07-18

But bankruptcy courts have jurisdiction over all cases under Title 11 of the U.S. Code, see 28 U.S.C. § 157, and Mr. Emiabata cites no authority for the proposition that Mrs. Emiabata’s concurrent bankruptcy proceeding in Connecticut divested the Bankruptcy Court in the District of Columbia of jurisdiction over his individual petition.
Read the full opinion on CourtListener →

Section 157 supports a bankruptcy court’s authority to hear a petition even when the debtor’s spouse has simultaneous bankruptcy proceedings in another district.

In re: Philip Emiabata · filed 2025-06-26

The bankruptcy court had jurisdiction pursuant to 28 U.S.C. § 157 and District Court Local Bankruptcy Rule 5011-1(a), and the simultaneous proceedings in the District of Connecticut brought by appellant’s wife did not divest the bankruptcy court of jurisdiction.
Read the full opinion on CourtListener →

Bankruptcy court jurisdiction is confined to Bankruptcy Code cases and proceedings arising under, arising in, or related to a bankruptcy case.

Peyton v. Allison · filed 2025-06-27(a)(1)

The bankruptcy court properly dismissed Petyon’s adversary proceeding for lack of subject matter jurisdiction because the bankruptcy court’s jurisdiction is confined to cases under the Bankruptcy Code and proceedings “arising under [the Bankruptcy Code] or arising in or related to” the bankruptcy case.
Read the full opinion on CourtListener →

Noncore proceedings related to a bankruptcy case

Section 157(c)(1) permits a bankruptcy judge to hear a noncore proceeding related to a bankruptcy case.

McDavid v. McDavid · filed 2022-11-29(c)(1)

With respect to the remainder of the claims asserted in the complaint, this court has “related to” jurisdiction. 28 U.S.C. § 157(c)(1) provides “[a] bankruptcy judge may hear a proceeding that is not a core proceeding but that is otherwise related to a case under title 11.”
Read the full opinion on CourtListener →

Section 157(c)(1) gives bankruptcy courts authority over proceedings related to a bankruptcy case.

Viva Inn, Inc. v. Amtrust Financial Services Inc · filed 2023-04-13(c)(1)

This Court has related to jurisdiction over this matter pursuant to 28 U.S.C. § 157(c)(1).
Read the full opinion on CourtListener →

Section 157(b) and (c) did not provide core or non-core jurisdiction over a post-confirmation claim objection concerning property that had revested in the debtors.

In re: Khamla Sihabouth and Manysay Sihabouth · filed 2014-07-02(b), (c)

The bankruptcy court did not have jurisdiction over the claim-objection adversary proceeding under 28 U.S.C. §§ 157(b) or (c) (establishing core and non-core bankruptcy court jurisdiction) because debtors’ challenge to BONY’s ownership of the debt came after confirmation of their FAP.
Read the full opinion on CourtListener →

Section 157(c)(1) permits a bankruptcy judge to hear a noncore proceeding if, at filing, its outcome could conceivably affect the bankruptcy estate.

MTE Holdings LLC v. · filed 2025-05-07(c)(1)

On de novo review, In re Resorts Int’l, Inc., 372 F.3d 154, 160 (3d Cir. 2004), we reject Chenault’s frivolous challenge to the Bankruptcy Court’s jurisdiction. ... 28 U.S.C. § 157(c)(1) authorizes a bankruptcy judge to “hear a proceeding that is not a core proceeding but that is otherwise related to a case under title 11.” A proceeding is “related to” a case under title 11 when the outcome of the proceeding “could conceivably have an[] effect on the estate being administered in bankruptcy.” ... Courts make this jurisdictional determination at the time of a case’s filing. ... Thus, it was plain at the time of filing that Chenault’s lawsuit could conceivably have affected MDC’s bankruptcy estate.
Read the full opinion on CourtListener →

Section 157(c)(1) permits a bankruptcy judge to hear a noncore proceeding related to a bankruptcy case, including an insurance coverage dispute whose outcome may affect estate administration.

CivilGEO, Inc. v. Hiscox Insurance Company · filed 2026-05-08(c)(1)

Section 157(c)(1) provides that “a bankruptcy judge may hear a proceeding that is not a core proceeding but that is otherwise related to a case under title 11.” 28 U.S.C. § 157 (c)(1). ... But the matter is “related to” the bankruptcy proceeding because the outcome of this Court’s decision may impact the administration of the estate.
Read the full opinion on CourtListener →

Section 157(a) does not support bankruptcy jurisdiction over counterclaims that can no longer affect property in the bankruptcy estate.

LifeUSA Insurance v. Green · filed 2002-07-23(a)

But even though the trustee never abandoned the counterclaims, the trustee rejected the LifeUSA policy on which the counterclaims were based, and those claims could no longer affect the amount of property in the bankruptcy estate. Thus, the bankruptcy court properly dismissed Green’s counterclaims. See 28 U.S.C. § 157(a); In re FedPak Sys., Inc., 80 F.3d 207, 213-14 (7th Cir.1996).
Read the full opinion on CourtListener →

Core proceedings involving the debtor-creditor relationship

Section 157(b)(2)(O) covers a bankruptcy court’s approval of a settlement that adjusts the debtor-creditor relationship, even when the settled claim arose from a criminal forfeiture judgment.

Bala v. PWE Enters., Inc. (In re Racing Servs., Inc.) · filed 2018-11-28(b)(2)(O)

In approving the Settlement Agreement, the Court never had to interpret or apply any criminal statutes. The Bankruptcy Court simply exercised authority over the adjustment of the debtor-creditor relationship, a key facet of a bankruptcy court's jurisdiction. 28 U.S.C. § 157(b)(2)(O).
Read the full opinion on CourtListener →

Section 157(b)(2)(O) includes proceedings affecting the adjustment of the debtor-creditor relationship among core proceedings.

City of Detroit, Michigan · filed 2023-06-26(b)(2)(O)

This is a core proceeding under 28 U.S.C. § 157(b)(2)(O), because it is a proceeding “affecting... the adjustment of the debtor-creditor . . . relationship.”
Read the full opinion on CourtListener →

Core proceedings

Section 157 permits a bankruptcy court to hear and determine a core proceeding involving the dischargeability of a particular debt.

Hill v. Der (In Re Der) · filed 1990-03-05(b)(1), (b)(2)(I)

The instant complaint is within the subject matter jurisdiction of the bankruptcy court because the controversy is a core proceeding arising under ... title 11 ... involving determinations as to the dis-chargeability of particular debts, which this Court may hear and determine.
Read the full opinion on CourtListener →

Section 157(b)(2)(H) and (K) do not make a fraudulent transfer or lien dispute a core proceeding when the property cannot be recovered for the bankruptcy estate or is not estate property.

Barber · filed 2025-11-07(b)(2)(H), (K)

The Defendants assert that the Plaintiff’s claims are core, relying on two jurisdictional provisions, 28 U.S.C. §§ 157(b)(2)(H) (proceedings to determine, avoid or recover fraudulent conveyances), and (K) (determinations of the validity, extent or priority of liens). Both of these jurisdictional provisions, however, assume that the property to be recovered, or the determination of the extent and priority of liens, involves property of the bankruptcy estate or property that can come into the bankruptcy estate by virtue of an avoidance and recovery action. ... The Court lacks core jurisdiction over actions to recover alleged fraudulent transfers of properties that cannot be recovered for the benefit of the estate, or to determine the validity and priority of liens on property that is not property of the estate.
Read the full opinion on CourtListener →

Section 157 treats matters involving administration of a bankruptcy case, including the automatic stay and dismissal, as core proceedings.

ARMIN DIRK VAN DAMME · filed 2025-03-13(b)(1), (b)(2)(A), (b)(2)(G)

This necessarily included the continuation or termination of the automatic stay under § 362(c)(3), and the dismissal of the chapter 11 under § 1112(b), as such matters involving the administration of the bankruptcy are core matter under 28 U.S.C. §§ 157(b)(2)(A) and (G), which necessarily arise in, or under, for purposes of jurisdiction over the bankruptcy under 28 U.S.C. § 157(b)(1).
Read the full opinion on CourtListener →

Section 157(b)(2)(A), (K), and (O) classifies this dispute over secured status and a willful stay violation as a core bankruptcy proceeding.

Byman v. RRL Capital Investments, LLC · filed 2023-09-07(b)(2)(A), (K), and (O)

The pending dispute before this Court is a core proceeding pursuant to 28 U.S.C. § 157(b)(2)(A), (K), and (O).
Read the full opinion on CourtListener →

Section 157(b)(2) treats plan confirmation and case conversion as core bankruptcy proceedings that a bankruptcy court may finally decide.

M.A.R. DESIGNS & CONSTRUCTION, INC. · filed 2023-09-22(b)(2)(A), (L), (O)

Here, the confirmation of a plan and conversion of a bankruptcy case are core proceedings pursuant to 28 U.S.C. § 157(b)(2)(A), (L) and (O).
Read the full opinion on CourtListener →

Section 157(b)(2)(B) and (I) treat the proceeding as core, giving the bankruptcy court statutory authority to enter a final order.

Tomlinson v. Clem (In re Clem) · filed 2017-12-21(b)(2)(B), (b)(2)(I)

This is a statutory core proceeding, pursuant to 28 U.S.C. § 157(b)(2)(B) and (I) ; thus, the bankruptcy court has statutory authority to enter a final order.
Read the full opinion on CourtListener →

Section 157(b)(2)(B) treats a claim supported by a proof of claim against the debtor as a core proceeding that the bankruptcy court may resolve by final order.

Apache Corp. v. Castex Offshore, Inc. (In re Castex Energy Partners, LP) · filed 2018-02-01(b)(2)(B)

Although this alleged breach of contract is a state law claim, Apache's proof of claim in the Castex Debtors' bankruptcy brings it within an enumerated example of a core proceeding under 28 U.S.C. § 157(b)(2)(B).
Read the full opinion on CourtListener →

Section 157(b)(2) does not treat a breach of contract dispute between two nondebtors as a core bankruptcy proceeding.

Stanley Jacobs Prod., Ltd. v. 9472541 Can. Inc. (In re Thane Int'l, Inc.) · filed 2018-02-21(b)(2)

However, further discussion of the parties' relationship, including specific damages, is beyond this Court's jurisdiction. ... The Court does not find that the underlying dispute-a breach of contract claim-between SJPL and New Thane satisfies this Circuit's jurisdictional standard.
Read the full opinion on CourtListener →

Section 157(b)(2)(I) treats determinations of the dischargeability of particular debts as core proceedings.

Dulles Elec. & Supply Corp. v. Shaffer (In re Shaffer) · filed 2018-02-27(b)(2)(I)

Determinations as to the dischargeability of particular debts are "core" proceedings within the meaning of 28 U.S.C. § 157(b)(2)(I).
Read the full opinion on CourtListener →

Section 157 gives bankruptcy courts authority to enter final judgment in core proceedings, including proceedings to enforce a discharge injunction.

In re Haltermon · filed 2018-02-27(b)

Pursuant to 28 U.S.C. § 157(b)(A) and (O), this is a core proceeding in which the Court possesses the authority to enter final judgment.
Read the full opinion on CourtListener →

Section 157(b)(2)(H) lists fraudulent conveyance actions as core proceedings; an action invoking a substantive right under the Bankruptcy Code qualifies as core even if it also rests on state law.

First Bank of Dalton v. Manton Family P'ship, LLLP (In re Manton) · filed 2018-02-28(b)(2)(H)

Here, the Fraudulent Conveyance Action is a core proceeding in bankruptcy because (1) fraudulent conveyance is specifically listed as a core proceeding under 28 U.S.C.S. § 157(b)(2), and (2) it invokes a substantive right created by § 544 of the Bankruptcy Code.
Read the full opinion on CourtListener →

Section 157(b)(2)(A) does not treat a debtor’s claims against private chapter 7 counsel as matters concerning estate administration when counsel had no role in administering the estate.

In re: Anita Holcomb · filed 2018-04-25(b)(2)(A)

Nor do the allegations constitute any of the core jurisdiction matters listed in 28 U.S.C. § 157(b) which “arise in” a case under Title 11 and essentially are proceedings that would not exist outside of bankruptcy. ... Debtor’s allegations against Altagen pertain solely to his representation as her chapter 7 private attorney. As such, Altagen’s duties and representation of Debtor did not involve the administration of the bankruptcy estate as that was the chapter 7 trustee’s role. Accordingly, Debtor’s claims against Altagen do not impact the handling and administration of her estate and thus are easily separable from the bankruptcy case.
Read the full opinion on CourtListener →

Section 157(b)(2)(A) covers a motion for leave to file counterclaims against a liquidating trustee as a core proceeding concerning estate administration.

In re World Mktg. Chi., LLC · filed 2018-04-26(b)(2)(A)

This matter is a core proceeding pursuant to 28 U.S.C. § 157(b)(2)(A), as a motion for leave to file counterclaims against a liquidating trustee is a matter which concerns the administration of the estate, and as such, this court may determine the matter.
Read the full opinion on CourtListener →

Section 157(b)(2)(B) treats the allowance or disallowance of claims against a bankruptcy estate as a core proceeding.

In re Pioneer Carriers, LLC · filed 2018-04-27(b)(2)(B)

Further, it is a core proceeding under 28 U.S.C. § 157(b)(2)(B) because it involves the allowance or disallowance of claims against the estate-namely, the TWC's claims for employment taxes on wages paid to alleged employees of the Debtor.
Read the full opinion on CourtListener →

Section 157(b)(2) treats claim allowance and disallowance, and estate counterclaims against people who filed claims, as core proceedings.

Penson Techs. LLC v. Schonfeld Grp. Holdings LLC (In re Penson Worldwide) · filed 2018-05-21(b)(2)(B), (C)

Each count in the Complaint is an enumerated core proceeding, Counts IV and V (objection to claim and declaration on setoff) fall under § 157(b)(2)(B), allowance or disallowance of claims against the estate. Counts I-III fall under § 157(b)(2)(C), counterclaims by the estate against persons filing claims against the estate.
Read the full opinion on CourtListener →

Section 157(b) covers listed core proceedings and proceedings that invoke a substantive Bankruptcy Code right or could arise only in bankruptcy; state law claims against a debtor's affiliate do not qualify on those grounds.

Superior Contracting Grp. Inc. v. Rachmale (In re LTC Holdings, Inc.) · filed 2018-06-12(b)

The current Proceeding, which asserts a series of state law claims against a third-party affiliated with the Debtors, does not fulfill any of these requirements.
Read the full opinion on CourtListener →

Section 157(b)(2)(I) treats determinations of the dischargeability of particular debts as core proceedings in which a bankruptcy court may enter final judgment.

Elizabeth W. Ackerman Trust v. Ackerman (In re Ackerman) · filed 2018-06-25(b)(2)(I)

It is a core proceeding within the meaning of 28 U.S.C. § 157(b)(1) and (b)(2)(I) (core proceedings include determinations of the dischargeability of particular debts). The bankruptcy court accordingly has authority to enter final judgment on the complaint.
Read the full opinion on CourtListener →

Section 157(b)(2)(B) treats objections to proofs of claim as core proceedings, but a request to reallocate a nondebtor's prepetition tax payments is not a core proceeding under that provision.

In re Donaldson · filed 2018-07-02(b)(2)(B)

While an objection to a proof of claim is, by definition, a core proceeding under 28 U.S.C. § 157(b)(2)(B), the relief requested by the Debtors is not.
Read the full opinion on CourtListener →

Section 157(b)(2)(A) treats a dispute affecting the administration of a debtor's bankruptcy estate as a core proceeding.

Gruppo Formstar LLC v. FM Forrest, Inc. (In re FM Forrest, Inc.) · filed 2018-07-18(b)(2)(A)

This dispute is a core proceeding pursuant to 28 U.S.C. § 157(b)(2)(A) because it is a matter affecting the administration of the Debtor's Chapter 7 estate.
Read the full opinion on CourtListener →

Section 157(b)(2)(A) and (G) covers requests to confirm termination of the automatic stay and reconsider its scope as core proceedings on which a bankruptcy court may enter final judgment.

In re Goodrich · filed 2018-07-20(b)(2)(A), (G)

The Court declares the Movant's requests for confirmation of stay termination and reconsideration of the Court's interpretation of § 362(c)(3)(A), and the Debtor's opposition to those requests, constitute a core proceeding for purposes of ... 28 U.S.C. § 157(b)(2)(A) & (G), over which this Court has constitutional authority to enter a final judgment.
Read the full opinion on CourtListener →

Section 157(b)(2)(A) treats matters concerning administration of the bankruptcy estate as core proceedings, including an accounting ordered in connection with that administration.

Brinkman Portillo Ronk APC v. Michael W. Carmel Limited · filed 2019-09-19(b)(2)(A)

As in Harris Pine Mills, the Bankruptcy Court in this case ordered an accounting in conjunction with administration of the bankruptcy estate. Under 28 U.S.C. § 157(b)(2)(A), “matters concerning the administration of the bankruptcy estate” are core proceedings.
Read the full opinion on CourtListener →

Section 157(b)(2) does not make state-law claims core proceedings merely because they may affect administration of the bankruptcy estate.

The Bradley A. Malkin Family Limited Partnership v. Sanchez · filed 2019-10-17(b)(2)

Admittedly, as plaintiffs contend, the instant action may arguably “concern[] the administration of the estate; allowance or disallowance of claims against the estate . . .; [or] . . . affect[] the liquidation of the assets of the estate” under § 157(b)(2) subsections (A), (B), or (O). ... In light of the Ninth Circuit’s holding in In re Castlerock Properties, the court finds that plaintiff’s claims are a non-core proceeding.
Read the full opinion on CourtListener →

Section 157(b)(2) permits bankruptcy judges to hear and determine core proceedings concerning Chapter 11 plan terms and the discharge status of particular debts.

Dragnea v. Dragnea · filed 2019-10-29(b)(2)

Disputes regarding terms of Chapter 11 plans and the discharge status of particular debts are core proceedings arising “in” and “under” title 11 that a bankruptcy judge may hear and determine. 28 U.S.C. §§ 157(b)(2)(B), (I), (J), (L), and (O) & 1334(b).
Read the full opinion on CourtListener →

Section 157 treats a proceeding to enforce a confirmed bankruptcy plan as core when the proceeding that produced the plan was core.

Gray v. CPF Associates LLC · filed 2020-03-04(b)

Matters concerning the bounds of the bankruptcy estate necessarily “arise under” or “arise in” a case under the bankruptcy code, and therefore the proceedings that produced the confirmed plan were “core”—a fact which Appellants do not, and cannot, dispute—meaning subsequent proceedings to enforce those orders were “core” as well.
Read the full opinion on CourtListener →

Section 157 classifies determinations of the dischargeability of particular debts as core bankruptcy proceedings.

Moreno v. Bowen · filed 2020-04-23(b)(2)(I)

Consequently, the Court finds that Plaintiff’s action for dischargeability is a core proceeding.
Read the full opinion on CourtListener →

Section 157 permits a bankruptcy court to enter final judgment on core claims involving the administration of a confirmed plan’s trust.

In re Western Asbestos Settlement Trust · filed 2022-09-21(b)(1)

Nonetheless, the Court finds that the Bankruptcy Court did not exceed its jurisdiction and properly entered judgment. ... The question thus becomes whether Appellants’ personal injury and wrongful death claims were “core claims.” This Court finds that they are “core claims.”
Read the full opinion on CourtListener →

Section 157(b)(2)(F) and (H) classify proceedings to avoid or recover preferences and fraudulent transfers as core proceedings.

Gold v. Myers Controlled Power, LLC (In re Truland Grp., Inc.) · filed 2018-07-23(b)(2)(F), (H)

This is a core proceeding under 28 U.S.C. §§ 157(b)(2)(F) (proceedings to determine, avoid or recover preferences) and (H) (proceedings to determine, avoid or recover fraudulent transfers).
Read the full opinion on CourtListener →

Section 157(b)(2) treats proceedings affecting estate administration, lien validity or priority, and liquidation of estate assets as core proceedings.

In re Sawtelle Partners, LLC · filed 2019-10-23(b)(2)(A), (K), (O)

The Court concludes that the Bankruptcy Court had jurisdiction over the first and second causes of action in the adversary proceedings because they arose under the Bankruptcy Code and in a bankruptcy proceeding. These claims affected the administration of the Sawtelle estate, involved determinations of the validity, extent, or priority of liens, and affected the liquidation of the assets of the estate and the adjustment of debtor-creditor relationships. See 28 U.S.C. § 157(b)(2)(A), (K), (O).
Read the full opinion on CourtListener →

Section 157(b)(2) classifies claim allowance and dischargeability matters as core bankruptcy proceedings.

Turbine Powered Technology, LLC v. CROWE · filed 2020-02-20(b)(2)(B), (b)(2)(I), (b)(2)(J)

Although the substance of the underlying claims involves disputes arising under state law, the claim allowance and dischargeability components of this adversary proceeding are clearly core proceedings that implicate federal bankruptcy law.
Read the full opinion on CourtListener →

Section 157(b)(1) gives bankruptcy courts authority to enter final orders in core proceedings concerning administration of the estate.

U.S.A. DAWGS, INC. · filed 2022-10-07(b)(1)

Moreover, 28 U.S.C. § 157(b)(1) designates matters concerning the administration of the estate as core proceedings in which the bankruptcy court has the authority to enter final orders and judgments.
Read the full opinion on CourtListener →

Section 157(b)(2)(B) treats a debtor’s malpractice claim tied to an objection to counsel’s proof of claim for fees as a core proceeding.

In re Stephen R Brown · filed 2023-06-02(b)(2)(B)

This Court sides with the reasoning set forth in the Report and Recommendation and finds Plaintiff’s malpractice claim is a core proceeding under 28 U.S.C. § 157(b)(2)(B).
Read the full opinion on CourtListener →

Section 157(b)(2)(B) treats a debtor’s malpractice claim tied to an objection to counsel’s proof of claim for legal fees as a core proceeding.

Brown v. Newman Du Wors LLP · filed 2023-06-02(b)(2)(B)

This Court sides with the reasoning set forth in the Report and Recommendation and finds Plaintiff’s malpractice claim is a core proceeding under 28 U.S.C. § 157(b)(2)(B).
Read the full opinion on CourtListener →

Section 157(b)(2)’s list of core matters is nonexclusive; a motion to determine the scope of the automatic stay is a core matter when analogous to a motion to terminate, annul, or modify the stay.

Natache D Rinegard-Guirma · filed 2023-08-04(b)(2)

Both motions seek determinations of the scope of the automatic stay. That type of motion is not included in the list of core matters in 28 U.S.C. § 157(b)(2). But the list is nonexclusive, and the motions are analogous to ... motions to terminate, annul, or modify the automatic stay, which do appear in that list. ... The motions are thus core matters that I may hear and determine and as to which I may enter appropriate orders.
Read the full opinion on CourtListener →

Section 157(b)(2)(O) classifies proceedings affecting the liquidation of estate assets or the adjustment of the debtor-creditor relationship as core proceedings.

Rodriguez v. Smith · filed 2023-08-04(b)(2)(O)

The pending dispute before this Court is a core proceeding pursuant to 28 U.S.C. § 157(b)(2)(O).
Read the full opinion on CourtListener →

Section 157(b)(2)(B) treats objections to exemptions as core bankruptcy proceedings.

Benny R. Knight, Sr. · filed 2023-08-07(b)(2)(B)

This proceeding is core under 28 U.S.C. § 157(b)(2)(B).
Read the full opinion on CourtListener →

Section 157(b)(2)(G) classifies motions for relief from the automatic stay as core bankruptcy matters.

AP Orangevale, LLC · filed 2023-08-08(b)(2)(G)

A motion for relief from stay is a core matter under § 157(b)(2)(G).
Read the full opinion on CourtListener →

Section 157(b) treats a trustee’s motion to approve a settlement as a core proceeding when it concerns estate administration, claim allowance, and adjustment of the debtor-creditor relationship.

In re: Joseph L. Sanders · filed 2023-08-09(b)(2)(A), (B), (O)

Further, Congress provided in 28 U.S.C. § 157(b) a list of 16 examples of core proceedings, which included (A) matters concerning the administration of the estate; (B) allowance or disallowance of claims against the estate. . .; (O) other proceedings affecting the liquidation of the assets of the estate or the adjustment of the debtor-creditor . . . relationship, except personal injury tort or wrongful death claims. The Settlement Motion implicates each of the three examples.
Read the full opinion on CourtListener →

Section 157 treats disputes over the allowance of claims as core proceedings that a bankruptcy court may hear and decide.

John Brancato · filed 2023-08-09(b)(2)(B)

This is a core proceeding under 28 U.S.C. § 157(b)(2)(B) that the Court may hear and decide.
Read the full opinion on CourtListener →

Section 157(b)(2) treats confirmation of a bankruptcy plan as a core proceeding that the bankruptcy court may decide.

Keith Steven Patrick Gilbert · filed 2023-08-09(b)(2)

Confirmation of the Plan is a core proceeding under 28 U.S.C. § 157(b)(2), and this Court has exclusive jurisdiction to determine whether the Plan complies with the applicable provisions of the Bankruptcy Code and should be confirmed.
Read the full opinion on CourtListener →

Section 157 treats a motion to enforce the automatic stay as a core proceeding that a bankruptcy court may finally decide.

Pa Co-Man, Inc. · filed 2023-08-11(b)(2)

The Motion to Enforce the Automatic Stay is a core proceeding which the Court has jurisdiction to hear and decide on a final basis.
Read the full opinion on CourtListener →

Section 157 permits bankruptcy judges to hear core proceedings, including determinations of whether particular debts are dischargeable.

Anthony J. Wallace - Adversary Proceeding · filed 2023-08-18(b)(2)(I)

Bankruptcy judges have authority to hear “all core proceedings arising under title 11” including “determinations as to the dischargeability of particular debts.” 28 U.S.C. §157(b)(2)(I). Subject-matter jurisdiction is secure.
Read the full opinion on CourtListener →

Section 157 permits a bankruptcy court to enter final judgment in a core proceeding.

Sommers v. Offshore Marine Contractors, Inc. · filed 2023-08-18(b)(1), (b)(2)

This is a core proceeding pursuant to 28 U.S.C. §§ 157(b)(1) and (b)(2). The bankruptcy court has the power to enter a final judgment in this adversary proceeding, subject to traditional rights of appeal.
Read the full opinion on CourtListener →

Section 157(b)(2) does not treat a creditor’s effort to add an alter ego debtor to a judgment on a prepetition state law claim as a core proceeding.

Speziali v. Viper Room Sunset, LLC · filed 2023-08-21(b)(2)

Neither Speziali’s underlying claims, which have been reduced to the Default Judgment, nor the effort to add Feinstein as an alter ego debtor for those claims, is a “core” proceeding under 28 U.S.C. §§ 157(b)(2)(A), (O), or (L).
Read the full opinion on CourtListener →

Section 157(b)(2) treats claims for violations of the automatic stay and discharge injunction as core proceedings.

Ohai v. PNC Bank National Association, Inc. · filed 2023-08-23(b)(2)

The Court has subject matter jurisdiction over Plaintiff’s claims pursuant to 28 U.S.C. § 1334(b) and 28 U.S.C. § 157(a), and the claims of violating the automatic stay and the discharge injunction are core proceedings under 28 U.S.C. § 157(b)(2)(A), (G), & (O).
Read the full opinion on CourtListener →

Section 157(b) treats claims to enforce the automatic stay and discharge injunction as core proceedings that a bankruptcy court may hear even after the bankruptcy case closes.

Ohai v. PNC Bank National Association, Inc. · filed 2023-08-23(b)

Pursuant to 28 U.S.C. § 1334(b) and 28 U.S.C. § 157(b), this Court may exercise jurisdiction in three categories of civil proceedings: those that arise under title 11, those that arise in cases under title 11, and those that relate to cases under title 11. ... Such proceedings are core proceedings “arising under” the Bankruptcy Code, irrespective of whether the case is reopened, and the Court does not lose jurisdiction to determine those issues just because the case is closed.
Read the full opinion on CourtListener →

Section 157 treats bankruptcy petition preparer proceedings under § 110 as core proceedings because they invoke substantive rights under the Bankruptcy Code.

Foreman · filed 2023-08-23(b)

While claims under 11 U.S.C. § 110 are not enumerated core proceedings under 28 U.S.C. § 157, they invoke substantive rights established by the Bankruptcy Code.12 Therefore, the instant proceedings are core.
Read the full opinion on CourtListener →

Section 157(b)(2)(B) classifies disputes over exemptions from a bankruptcy estate as core proceedings.

Whitney J. Harding · filed 2023-08-25(b)(2)(B)

Matters involving the exemption of property from a bankruptcy estate are core proceedings. 28 U.S.C. §157(b)(2)(B).
Read the full opinion on CourtListener →

Section 157 treats this dischargeability adversary proceeding as a core proceeding in which the bankruptcy court may enter final judgment.

SMGB, LLC v. Cross · filed 2023-08-25(b)(2)(A), (B), and (I)

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), (B), and (I), and meets all constitutional standards for the proper exercise of full judicial power by this Court.
Read the full opinion on CourtListener →

Section 157(b)(2)(A) and (B) covers as a core proceeding an adversary action to determine whether covenants or easements require a debtor to provide water to neighboring lots.

Green Acres MHP LLC v. Dunlop, Jr. · filed 2023-08-28(b)(2)(A) and (B)

This is a core proceeding under 28 U.S.C. § 157(b)(2)(A) and (B).
Read the full opinion on CourtListener →

Section 157(b)(3) prevents a proceeding from being classified as noncore solely because state law may affect its resolution.

Wyly · filed 2023-08-29(b)(3)

The fact that a dispute is based on a “state-created right,” as the Wylys put it, does not alone remove that dispute from the category of core bankruptcy proceedings. Rather, the Bankruptcy Code provides 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).
Read the full opinion on CourtListener →

Notes 6301–6450 of 6,735, oldest cases first.

Which of these rulings fit your facts?

Describe your situation under 28 U.S.C. § 157. Ezel checks it against the cases on this page and answers with citations.

Opens in Ezel Pro.

  • Checks the law as it stands today, not only this page
  • Cites every source it relies on, so you can verify it
  • Chat, drafting and research in one workspace