Ritzen Group, Inc. v. Jackson Masonry, LLC explained

Litigants:Ritzen Group, Inc. v. Jackson Masonry, LLC
Arguedate:November 13
Argueyear:2019
Decidedate:January 14
Decideyear:2020
Fullname:Ritzen Group, Inc. v. Jackson Masonry, LLC
Usvol:589
Parallelcitations:140 S. Ct. 582; 205 L. Ed. 2d 419
Docket:18-938
Oralargument:https://apps.oyez.org/player/#/roberts10/oral_argument_audio/24935
Opinionannouncement:https://www.supremecourt.gov/opinions/19pdf/18-938_l6gn.pdf
Prior:
  • Ritzen Grp., Inc. v. Jackson Masonry, LLC, No. 3:17-CV-00806, 2018 WL 558837 (M.D. Tenn. Jan. 25, 2018)
  • Stay granted, 589 B.R. 601 (M.D. Tenn. 2018)
  • Affirmed sub nom. In re Jackson Masonry, LLC, 906 F.3d 494 (6th Cir. 2018)
  • Cert. granted 139 S. Ct. 2614 (2019)
Holding:An unreserved adjudication of a motion of relief from automatic stay by a bankruptcy court yields a final, appealable order
Majority:Ginsburg
Joinmajority:unanimous

Ritzen Group, Inc. v. Jackson Masonry, LLC, 589 U.S. ___ (2020) was a United States Supreme Court case from the October 2019 term. In a unanimous opinion, the Supreme Court ruled that "when the bankruptcy court unreservedly grants or denies relief", in this case on a motion for relief from an automatic stay, that decision presents a final order that may be appealed. In a 12-page opinion the Court relied upon its own precedent in Bullard v. Blue Hills Bank to affirm the court below.

Background

Ritzen Group, Inc. agreed to buy land in Nashville, Tennessee from Jackson Masonry, LLC but the land sale was never effected. Ritzen sued for breach of contract in state court but, just days before the trial, Jackson filed for bankruptcy which triggered the automatic stay provision for all lawsuits. Ritzen sued in federal court asking that the state court be compelled to hear the case arguing that the bankruptcy was filed in bad faith.