The Supreme Court of the United States announced decisions in two cases this morning:
Coleman v. Johnson, No. 11-1053: After petitioner’s conviction was affirmed in state court, he sought a writ of habeas corpus in federal district court. The district court denied habeas relief, but the Third Circuit reversed, holding that the evidence at trial was insufficient to support petitioner’s conviction under the standard set forth in Jackson v. Virginia, 443 U. S. 307 (1979). Today, in a per curiam decision, the Supreme Court reversed the Third Circuit. The Court reiterated previous holdings that, on habeas review, “a federal court may not overturn a state court decision rejecting a sufficiency of the evidence challenge simply because the federal court disagrees with the state court. The federal court instead may do so only if the state court decision was ‘objectively unreasonable.’” Because the Third Circuit failed to afford due respect to the role of the jury and the state courts, its judgment was reversed and the case remanded.
The Court’s opinion is available
here.
RADLAX Gateway Hotel LLC v. Amalgamated Bank, No. 11-166: Petitioner debtors sought to confirm a “cramdown” bankruptcy plan over the respondent Bank’s objection. That plan proposed selling the debtors’ property at an auction and using the sale proceeds to repay the Bank. Under the proposed auction procedures, the Bank, a secured creditor, would not be permitted to bid for the property using the debt it is owed to offset the purchase price, a practice known as “credit-bidding.” The bankruptcy court denied the debtors’ request, and the Seventh Circuit affirmed, holding that the Bankruptcy Code does not permit debtors to sell an encumbered asset free and clear of a lien without permitting the lienholder to credit-bid. Today, the Supreme Court affirmed as well, holding that debtors may not obtain confirmation of a Chapter 11 cramdown plan that provides for the sale of collateral free and clear of a creditor’s lien, but does not permit the creditor to credit-bid at the sale.
The Court’s opinion is available
here.
The Court also granted review in one case:
Marx v. General Revenue Corp., No. 11-1175: Whether a prevailing defendant in a Fair Debt Collection Practices Act case may be awarded costs where the lawsuit was not brought in bad faith or for the purpose of harassment.