United States v. Miller
View Official PDFBelow are plain-language sections to help you understand what the Court decided in United States v. Miller and why it matters. Quotes are taken from the syllabus (the Court’s short summary at the start of the opinion).
Summary
A short, plain-English overview of United States v. Miller.
The Supreme Court addressed whether § 106(a) of the Bankruptcy Code waives sovereign immunity for state-law claims within a § 544(b) claim. The Court concluded that § 106(a)'s waiver applies only to the federal claim itself, not to state-law claims. The decision reversed the Tenth Circuit's affirmation of the lower courts' rulings.
Holding
The single most important “bottom line” of what the Court decided in United States v. Miller.
The Court held that Section 106(a)'s sovereign-immunity waiver applies only to a § 544(b) claim itself and not to state-law claims nested within that federal claim.
Constitutional Concepts
These are the Constitution-related themes that appear in United States v. Miller. Click a concept to see other cases that involve the same idea.
-
Why State Sovereign Immunity is relevant to United States v. Miller
The case primarily deals with the waiver of sovereign immunity under the Bankruptcy Code.
Syllabus excerpt (verbatim)Section 106(a)'s sovereign-immunity waiver applies only to a § 544(b) claim itself and not to state-law claims nested within that federal claim.
-
Why Judicial Review is relevant to United States v. Miller
The Court's decision involves interpreting statutory provisions and their interplay, which is a function of judicial review.
Syllabus excerpt (verbatim)Waivers of sovereign immunity function simply as 'prerequisite[s] for jurisdiction'—they do not create any new substantive rights or alter any pre-existing ones.
Key Quotes
Short excerpts from the syllabus in United States v. Miller that support the summary and concepts above.
Section 106(a)'s sovereign-immunity waiver applies only to a § 544(b) claim itself and not to state-law claims nested within that federal claim.
Waivers of sovereign immunity function simply as 'prerequisite[s] for jurisdiction'—they do not create any new substantive rights or alter any pre-existing ones.
The Court's precedents require construing sovereign-immunity waivers narrowly, with any ambiguities resolved in favor of the sovereign.
