Thursday, June 23, 2011

Supreme Court Finds Core Counterclaim Jurisdiction Unconstitutional, Sends Vickie Lynn Marshall Estate Packing

After fifteen years of litigation, two trips to the Supreme Court and the deaths of both of the original antagonists, the Supreme Court decided Stern v. Marshall, ___ U.S. ___ (2011). While Vickie Lynn Marshall, better known as Anna Nicole Smith, made a splash during her lifetime as a Playboy Playmate who married an aging oil billionaire, her posthumous legacy is the most important Supreme Court case on bankruptcy court jurisdiction since Northern Pipeline Construction Co. v. Marathon Pipe Line Co., 459 U.S. 813 (1982). It may also sow as much confusion as the latter case. You can find the opinion here.

The issue in Marshall was straightforward: does 28 U.S.C. §157(b)(2)(C) mean what it says-- that counterclaims to proofs of claim are core proceedings, and if so, is that grant of jurisdiction constitutional? In a 5-4 decision authored by Chief Justice Roberts, the Court concluded that §157(b)(2)(C) did authorize the bankruptcy court to determine a counterclaim to a proof of claim as a core proceeding, but that the statutory grant was unconstitutional. In doing so, the Chief laid out a manifesto on the meaning of Article III. Justice Scalia offered a curt concurring opinion and Justice Breyer wrote in dissent.

The Executive Summary

While the three opinions in the case make for compelling reading, the following two quotes from the beginning of the opinion carry the gist of it:

Chief Justice Roberts opened his opinion with a reference to Dickens’ Bleak House:

This “suit has, in course of time, become so complicated, that . . . no two . . . lawyers can talk about it for five minutes, without coming to a total disagreement as to all the premises. Innumerable children have been born into the cause: innumerable young people have married into it;” and, sadly, the original parties “have died out of it.” A “long procession of [judges] has come in and gone out” during that time, and still the suit “drags its weary length before the Court.”

Those words were not written about this case, see C. Dickens, Bleak House, in 1 Works of Charles Dickens 4–5 (1891), but they could have been. This is the second time we have had occasion to weigh in on this long-running dispute between Vickie Lynn Marshall and E. Pierce Marshall over the fortune of J. Howard Marshall II, a man believed to have been one of the richest people in Texas.


Although the history of this litigation is complicated, its resolution ultimately turns on very basic principles. Article III, §1, of the Constitution commands that “[t]he judicial Power of the United States, shall be vested in one supreme Court, and in such inferior Courts as the Congress may from time to time ordain and establish.” That Article further provides that the judges of those courts shall hold their offices during good behavior, without diminution of salary. Ibid. Those requirements of Article III were not honored here. The Bankruptcy Court in this case exercised the judicial power of the United States by entering final judgment on a common law tort claim, even though the judges of such courts enjoy neither tenure during good behavior nor salary protection. We conclude that, although the Bankruptcy Court had the statutory authority to enter judgment on Vickie’s counterclaim, it lacked the constitutional authority to do so.

Opinion, pp. 1-2.

For those who want the nitty, gritty details, here are several thousand more words about the opinion.

A Billionaire’s Death Paves the Way for the Destruction of Many Trees

On June 27, 1994, Vickie Lynn Smith married Howard Marshall. She was 26 and had been Playboy’s Playmate of the Year the prior year. He was 89. Howard passed away thirteen months later on August 4, 1995. However, the parties did not wait for his death to begin their legal battle.

In April 1995, Vickie filed suit in Probate Court in Texas seeking to invalidate Howard’s living trust and asserting that Howard son, Pierce, had tortiously interfered with her property rights in Howard’s assets. Pierce then filed suit against Vickie and two of her lawyers in Texas state court asserting that they had defamed him.

In January 1996, Vickie did what any destitute ex-stripper would have done and filed for chapter 11 relief in California. Pierce filed a dischargeability adversary and a proof of claim against Vickie. Vickie counterclaimed for tortious interference with an inter vivos gift, contending that Pierce had forged Howard’s name to a living trust and destroyed or suppressed a trust that Howard had asked his lawyers to draw up for Vickie’s benefit.

Things did not go well for Pierce in bankruptcy court. The Bankruptcy Court found that he had engaged in “massive discovery abuse.” Pierce then asked the District Court to withdraw the reference. The District Court initially indicated it would grant the motion but then reconsidered based on the fact that Pierce had voluntarily chosen the Bankruptcy Court forum.

The Bankruptcy Court commenced a trial on the adversary proceeding on October 25, 2009. It rendered a final judgment awarding Vickie $447 million on December 29, 2000.

Meanwhile, back in Texas, Vickie filed a parallel claim against Pierce in January 2000. Pierce defended asserting that there was not an agreement to be tortiously interfered with. After recovering a judgment against Pierce in Bankruptcy Court, Vickie non-suited her claims against Pierce in Texas Probate Court. The Bankruptcy Court initially ordered Pierce not to proceed, but changed its mind after Pierce represented that there was no risk of inconsistent judgments.

After a five month trial, the jury in the Probate Court returned a verdict adverse to Vickie on March 7, 2001. Among other things, the jury found that Howard had not agreed to make a gift to Vickie. The Probate Court entered a final judgment on December 27, 2001.

The two trials were a contrast in the evidence considered. The Bankruptcy Court did not allow Pierce to present any evidence because of his discovery abuse. On the other hand, the Probate Court heard 40 witnesses, including six days of testimony from Vickie Lynn and resulted in a jury verdict.

Up to the Supreme Court Round One

Pierce appealed the Bankruptcy Court judgment, contending among other things that the dispute was a non-core proceeding which must be reviewed de novo by the District Court. The District Court agreed that the claim was non-core and conducted additional hearings. It entered a judgment which affirmed the Bankruptcy Court’s findings on liability but reduced the damage award. This judgment was entered on March 7, 2002.

Pierce appealed to the Ninth Circuit which vacated the judgment, finding that the “probate exception” deprived the Bankruptcy Court of jurisdiction. Marshall v. Marshall, 392 F.3d 1118 (9th Cir. 2004). The Supreme Court disagreed and remanded the case to the Ninth Circuit. Marshall v. Marshall, 547 U.S. 293 (2006). You can read more about that opinion here. (Note: The original opinion in Marshall v. Marshall was the subject of the inaugural post for this blog).

Shortly after the remand, both Pierce and Vickie passed away within a few months of each other. This left the contest over the assets of Howard as a battle between the estates of Pierce and Vickie.

The Ninth Circuit Tangles With Jurisdiction Again

When the case went back to the Ninth Circuit, it reached the same result although for different reasons. Stern v. Marshall, 600 F.3d 1037 (9th Cir. 2010). (The caption of the case changed because Howard K. Stern was the executor of Vickie’s estate. However, it is Howard Stern the lawyer, rather than Howard Stern the radio shock jock). The Ninth Circuit basically held that 28 U.S.C. §157(b)(2)(C) did not mean what it said. While 28 U.S.C. §157(b)(2)(C) expressly provides that counterclaims to proofs of claim constitute core proceedings, the Ninth Circuit held that it only extended to counterclaims to the extent necessary to determine the proof of claim, but not to an affirmative recovery. Alternatively, it held that if §157(b)(2)(C) did extend to counterclaims in their entirety, that it was unconstitutional.

This set the stage for a second trip to the Supreme Court.

Bankruptcy Jurisdiction 101

As an introduction, Chief Justice Roberts summarized eight principles of Bankruptcy Court jurisdiction:

* District Judges have “original and exclusive jurisdiction of all cases under title 11.”

* Bankruptcy proceedings fall into three categories: those that arise under title 11, that that arise in a case under title 11 and those that are related to a case under title 11.

* District Courts may refer “any or all such proceedings to the bankruptcy judges of their district” and may withdraw the reference “for cause shown.”

* Since 1984, Bankruptcy Judges “have been appointed to 14-year terms by the courts of appeals for the circuits in which their district is located.”

* Bankruptcy Judges may enter final orders in “all core proceedings arising under title 11, or arising in a case under title 11.”

* Core proceedings include but are not limited to sixteen enumerated categories, including “counterclaims by [a debtor’s] estate against persons filing claims against the estate.”

* If the Bankruptcy Court can enter a final judgment, an aggrieved party has a right of appeal to the U.S. District Court.

* If a matter is not a core proceeding, then the Bankruptcy Court must submit proposed findings of fact and conclusions of law to the District Court for de novo review unless the parties consent to entry of a final judgment by the Bankruptcy Court.

Opinion, pp. 7-8.

Section 157(b)(2)(C) Means What It Says

Chief Justice Roberts found that Vickie’s counterclaim against Pierce was a core proceeding “under the plain text of §157(b)(2)(C).” This was a rebuke to the Ninth Circuit which had adopted the rather magical reasoning that a counterclaim was only a core proceeding to the extent that it reduced a claim against the estate, but not to the extent that it granted affirmative recovery.

The Chief then analyzed what the phrase “all core proceedings arising under title 11, or arising in a case under title 11” meant. This phrase is important because it identifies the types of proceedings that Bankruptcy Judges can enter final orders in. Pierce had suggested that the phrase was ambiguous and that there could be some core proceedings which neither arose under title 11 or in a case under title 11. The Court acknowledged that the phrase was ambiguous but concluded that “core proceedings are those that arise in a bankruptcy case or under Title 11.” Opinion, p. 10.

The Court also rejected the argument that core proceedings that did not arise under Title 11 nor in a Title 11 case should be “related to” proceedings.

Pierce argues that we should treat core matters that arise neither under Title 11 nor in a Title 11 case as proceedings “related to” a Title 11 case. Brief for Respondent 60 (internal quotation marks omitted). We think that a contradiction in terms. It does not make sense to describe a “core” bankruptcy proceeding as merely “related to” the bankruptcy case; oxymoron is not a typical feature of congressional drafting.

Opinion, p. 10.

Concluding its discussion of statutory interpretation, Chief Justice Roberts stated, “We agree with Vickie that §157(b)(2)(C) permits the bankruptcy court to enter a final judgment on her tortious interference counterclaim.” Opinion, p. 11.

The Court also shot down Pierce’s argument that the Bankruptcy Court lacked jurisdiction on Vickie’s defamation claim because it was a “personal injury tort claim.” Under §157(b)(5), “The District Court shall order 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 claim arose.” Pierce contended that this meant that the Bankruptcy Court lacked jurisdiction to hear these claims. Vickie contended that defamation was not a “personal injury tort” and that the statute was not jurisdictional. The Court declined the invitation to define the term “personal injury tort” and instead found that the section was not jurisdictional and could be waived. When Pierce waited 27 months to file his motion to withdraw reference, he waived his ability to seek a trial in the district court.

All About Article III

If the Opinion had stopped here, there would have been much rejoicing on Vickie’s side. However, it did not. “Although we conclude that§157(b)(2)(C) permits the Bankruptcy Court to enter final judgment on Vickie’s counterclaim, Article III of the Constitution does not.”

Article III of the Constitution vests the judicial power of the United States in the supreme court and “such inferior Courts as the Congress may from time to time establish.” While I am sure that District Court Judges don’t like to think of themselves as “inferior Courts,” at least the Constitution guaranties them life tenure and protection against reduction in pay. Bankruptcy Judges, being appointed under Article I of the Constitution, do not enjoy these protections.

The Chief described Article III as “an inseparable element of the constitutional system of checks and balances that both defines the power and protects the independence of the Judicial Branch.” Opinion, p. 16. It also “protects liberty.” Opinion, p. 17. In the Declaration of Independence , one of the grievances of the colonists was that King George “made Judges dependent on his Will alone, for the tenure of their offices and the amount and payment of their salaries.”

The Framers undertook in Article III to protect citizens subject to the judicial power of the new Federal Government from a repeat of those abuses. By appointing judges to serve without term limits, and restricting the ability of the other branches to remove judges or diminish their salaries, the Framers sought to ensure that each judicial decision would be rendered, not with an eye toward currying favor with Congress or the Executive, but rather with the “[c]lear heads . . . and honest hearts” deemed “essential to good judges.” 1 Works of James Wilson 363 (J. Andrews ed. 1896).

Opinion, p. 18. Thus, the Court’s consideration of the constitutionality of §157(b)(2)(C) is not just about which person in a black robe will decide a particular case or which estate of a dead person will receive a lot of money, but rather, it is a mighty bulwark protecting us against a new King George and his corrupt judges.

Public Rights and Private Lawsuits

While Article III jurisdiction is important in preventing tyranny, there is an exception for “public rights.”

The plurality in Northern Pipeline recognized that there was a category of cases involving “public rights” that Congress could constitutionally assign to “legislative” courts for resolution. That opinion concluded that this “public rights” exception extended “only to matters arising between” individuals and the Government “in connection with the performance of the constitutional functions of the executive or legislative departments . . . that historically could have been determined exclusively by those” branches. Id., at 67–68 (internal quotation marks omitted). A full majority of the Court, while not agreeing on the scope of the exception, concluded that the doctrine did not encompass adjudication of the state law claim at issue in that case.

Opinion, p. 19.

After Northern Pipeline, Congress tried again, creating bankruptcy courts appointed by the Court of Appeals and allowing them to enter final judgments in “core” proceedings only. Judgments in core proceedings were subject to only traditional appellate review with deference to judicial fact finding.

The Chief Justice then found that the Vickie Lynn Marshall case was just like the Northern Pipeline case in that

the Bankruptcy Court in this case exercise the “judicial Power of the United States” in purporting to resolve and enter final judgment on a state common law claim, just as the court did in Northern Pipeline. No “public right” exception excuses the failure to comply with Article III in doing so, any more than in Northern Pipeline.

Opinion, p. 21. The Court found that “Vickie’s claim is a state law action independent of the federal bankruptcy law and not necessarily resolvable by a ruling on the creditor’s proof of claim in bankruptcy.” Id.

So, what is a public right? We know that it is not a suit between two creditors, since that was the case in Northern Pipeline. We know that it is not a state law counterclaim by a debtor against a person filing a claim against the estate, since that is the holding in this case.

The public rights doctrine goes back to Murray’s Lessee v. Hoboken Land & Improvement Co., 18 How. 272 (1856). Here is how Chief Justice Roberts described the decision:

“To avoid misconstruction upon so grave a subject,” the Court laid out the principles guiding its analysis. Id., at 284. It confirmed that Congress cannot “withdraw from judicial cognizance any matter which, from its nature, is the subject of a suit at the common law, or in equity, or admiralty.” Ibid. The Court also recognized that “[a]t the same time there are matters, involving public rights, which may be presented in such form that the judicial power is capable of acting on them, and which are susceptible of judicial determination, but which congress may or may not bring within the cognizance of the courts of the United States, as it may deem proper.” Ibid.

Opinion, p. 22. Thus, the distinction was between public rights defined as

those arising “between the Government and persons subject to its authority in connection with the performance of the constitutional functions of the executive or legislative departments”

and private rights which are

the liability of one individual to another under the law as defined.

Opinion, p. 23. While it is not necessary for the government to be a party to an action to invoke the public rights doctrine, the Court

has continued . . . to limit the exception to cases in which the claim at issue derives from a federal regulatory scheme, or in which resolution of the claim by an expert government agency is deemed essential to a limited regulatory objective within the agency’s authority.

Opinion, p. 25.

While the discussion thus far was fairly general, the Court brought it back to the bankruptcy realm in discussing Granfinanciera, S.A. v. Nordberg, 492 U.S. 33 (1989). That case involved whether a defendant who had not filed a proof of claim was entitled to a jury trial in a fraudulent conveyance case.

In Granfinanciera we rejected a bankruptcy trustee’s argument that a fraudulent conveyance action filed on behalf of a bankruptcy estate against a noncreditor in a bankruptcy proceeding fell within the “public rights” exception. We explained that, “[i]f a statutory right is not closely intertwined with a federal regulatory program Congress has power to enact, and if that right neither belongs to nor exists against the Federal Government, then it must be adjudicated by an Article III court.” Id., at 54–55. We reasoned that fraudulent conveyance suits were “quintessentially suits at common law that more nearly resemble state law contract claims brought by a bankrupt corporation to augment the bankruptcy estate than they do creditors’ hierarchically ordered claims to a pro rata share of the bankruptcy res.” Id., at 56. As a consequence, we concluded that fraudulent conveyance actions were “more accurately characterized as a private rather than a public right as we have used those terms in our Article III decisions.” Id., at 55.7

Opinion, at 26-27.

Applying the Law to This Case

The Court clicked off the following reasons that Vickie Lynn’s counterclaim did not fall within the public rights exception:

* It was not a claim which could be pursued only by grace of the other branches of government.

* It was not a matter that historically could be determined only by the other branches.

* It did not flow from a federal regulatory scheme.

* It was not “completely dependent upon” adjudication of a claim created by federal law.

* It was a claim under state common law between two private parties.

The Court made an interesting observation about why consent to trial in the Article I court:

Pierce did not truly consent to resolution of Vickie’s claim in the bankruptcy court proceedings. He had nowhere else to go if he wished to recover from Vickie’s estate.

Opinion at 27. In Granfinanciera, the Supreme Court found that the defendant was entitled to a jury trial because he had not consented to the Bankruptcy Court’s jurisdiction by filing a proof of claim. Here, however, the Supreme Court is saying that even filing a claim does not constitute consent. More on this below.

Finally, this was not a case involving an

expert and inexpensive method for dealing with a class of questions of fact which are particularly suited to examination and determination by an administrative agency specially assigned to that task.

Opinion, p. 28.

The “experts” in the federal system at resolving common law counterclaims such as Vickie’s are the Article III courts, and it is with those courts that her claim must stay.


In summing up his public rights discussion, the Chief Justice stated:

What is plain here is that this case involves the most prototypical exercise of judicial power: the entry of a final, binding judgment by a court with broad substantive jurisdiction, on a common law cause of action, when the action neither derives from nor depends upon any agency regulatory regime. If such an exercise of judicial power may nonetheless be taken from the Article III Judiciary simply by deeming it part of some amorphous “public right,” then Article III would be transformed from the guardian of individual liberty and separation of powers we have long recognized into mere wishful thinking.

Opinion, p. 29. I think what the court was trying to say here was, “You don’t have jurisdiction. We really, really mean it.”

No Proof of Claim Waiver

In Katchen v. Landy, 382 U.S. 323 (1966) and Langenkamp v. Culp, 498 U.S. 42 (1990), the Supreme Court had held that a creditor who filed a proof of claim could be sued to recover a preference. The Court distinguished these cases on two grounds. First, the Court argued that the preference could be a ground for disallowing the claim, so that the preference claim was tied into allowance of the claim. Second, it found that the preference claim was created by the Bankruptcy Code and was part of the process of determining an equitable allocation of the assets of the debtor.

What’s the Big Deal?

Responding to concerns that its decision would radically change the workload of the Courts, Chief Justice Roberts stated:

We do not think the removal of counterclaims such as Vickie’s from core bankruptcy jurisdiction meaningfully changes the division of labor in the current statute; we agree with the United States that the question presented here is a “narrow” one. Brief for United States as Amicus Curiae 23.


Article III of the Constitution provides that the judicial power of the United States may be vested only in courts whose judges enjoy the protections set forth in that Article. We conclude today that Congress, in one isolated respect, exceeded that limitation in the Bankruptcy Act of 1984. The Bankruptcy Court below lacked the constitutional authority to enter a final judgment on a state law counterclaim that is not resolved in the process of ruling on a creditor’s proof of claim. Accordingly, the judgment of the Court of Appeals is affirmed.

Opinion, pp. 37, 38.

Justice Scalia Would Throw the Whole System Out

In a brief concurrence, Justice Scalia reaffirmed his prior concurrence in Granfinanciera that at a minimum, a public rights case must arise between the government and others, a conclusion that would render most bankruptcy court jurisdiction unconstitutional. He mused that it could possibly be constitutional for bankruptcy judges to adjudicate claims against the estate, but demurred that “the subject has not been briefed, and so I state no position on the matter.”

The Dissent

In a vigorous dissent, Justice Breyer, joined by Justices Ginsburg, Sotomayor and Kagan, argued that counterclaim jurisdiction is constitutional. The dissent placed a different emphasis upon the Court’s prior precedents to arrive at the opposite conclusion. In particular, the dissent took the majority to task for relying so heavily on the plurality opinion in Northern Pipeline instead of the more recent decisions in Thomas v. Union Carbide Agricultural Products Co., 473 U.S. 568 (1985) and Commodity Futures Trading Commission v. Schor, 478 U.S. 833 (1986).

The dissent also questioned the majority’s view that the opinion does not change all that much.

The majority predicts that as a “practical matter” today’s decision “does not change all that much.” Ante, at 36–37. But I doubt that is so. Consider a typical case: A tenant files for bankruptcy. The landlord files a claim for unpaid rent. The tenant asserts a counterclaim for damages suffered by the landlord’s (1) failing to fulfill his obligations as lessor, and (2) improperly recovering possession of the premises by misrepresenting the facts in housing court. (These are close to the facts presented in In re Beugen, 81 B. R. 994 (Bkrtcy. Ct. ND Cal. 1988).) This state-law counterclaim does not “ste[m] from the bankruptcy itself,” ante, at 34, it would not “necessarily be resolved in the claims allowance process,” ibid., and it would require the debtor to prove damages suffered by the lessor’s failures, the extent to which the landlord’s representations to the housing court were untrue, and damages suffered by improper recovery of possession of the premises, cf. ante, at 33-33. Thus, under the majority’s holding, the federal district judge, not the bankruptcy judge, would have to hear and resolve the counterclaim.

Why is that a problem? Because these types of disputes arise in bankruptcy court with some frequency. See, e.g., In re CBI Holding Co., 529 F. 3d 432 (CA2 2008) (statelaw claims and counterclaims); In re Winstar Communications, Inc., 348 B. R. 234 (Bkrtcy. Ct. Del. 2005) (same); In re Ascher, 128 B. R. 639 (Bkrtcy. Ct. ND Ill. 1991) (same); In re Sun West Distributors, Inc., 69 B. R. 861 (Bkrtcy. Ct. SD Cal. 1987) (same). Because the volume of bankruptcy cases is staggering, involving almost 1.6 million filings last year, compared to a federal district court docket of around 280,000 civil cases and 78,000 criminal cases. Administrative Office of the United States Courts, J. Duff, Judicial Business of the United States Courts: Annual Report of the Director 14 (2010). Because unlike the “related” non-core state law claims that bankruptcy courts must abstain from hearing, see ante, at 36, compulsory counterclaims involve the same factual disputes as the claims that may be finally adjudicated by the bankruptcy courts. Because under these circumstances, a constitutionally required game of jurisdictional ping-pong between courts would lead to inefficiency, increased cost, delay, and needless additional suffering among those faced with bankruptcy.

Dissent, pp. 16-17.

What Does It All Mean?

The difficulty with the Stern opinion is that it is a narrow opinion with a very broad rationale. While the holding merely invalidates 28 U.S.C. §157(b)(2)(C), it does so with a broad reading of the importance of the Article III judiciary and a narrow reading of the public rights exception. Lying underneath the opinion, there is a palpable feeling that Congress has gone too far in giving power to non-Article III adjuncts. To paraphrase a song, the majority’s lips say no, no, no (practical effect), but their eyes say yes, yes, yes.

Here are a few conclusions that can be drawn:

1. The opinion is about placement of jurisdiction rather than jurisdiction itself. The Supreme Court never said that the Bankruptcy Court lacked jurisdiction to "hear" the case; rather, it said that it lacked jurisdiction to enter a final judgment. It was the District Court which had jurisdiction to enter a final judgment. Because the District Court judgment came after the Probate Court judgment, the Probate Court judgment was entitled to full faith and credit and took precedence over the later District Court judgment.

2. The opinion will have its greatest impact on adversary proceedings. Contested matters, such as plans of reorganization and motions to lift stay would not be affected.

3. State law causes of action against non-debtor parties are non-core proceedings even if the other party has filed a proof of claim.

4. Fraudulent conveyance actions, even those arising under Section 548, may prove to be non-core.

5. Preference actions remain as core proceedings.

6. Even Justice Scalia would probably allow the Bankruptcy Court to determine an objection to claim on a good day.

For more opinions about what all this means, tune in to the State Bar of Texas’s Webinar, Stern v. Marshall: Handling State Claims After the Supremes Make It All Clear on July 12, 2011 at 10:00 a.m. Speaking will be Gerrit Pronske, former judge and law professor Glen Ayers and yours truly.

Editor's Note: The original version used the words "tortuous" and "tortuously" instead of "tortious" and "tortiously." This was an automatic correction made by Microsoft Word that I did not catch in proofing the article. According to, "tortious" means "of the nature of or pertaining to a tort." It derives from the Middle English "torcious" from the period 1350-1400. On the other hand, "tortuous" means "full of twists, turns or bends." It also derives from the Middle English of 1350-1400.

To correctly use the two words:

Vickie Lynn's tortious intereference claim took a tortuous trip through the court system.

Hat tip to Barbara Barron for pointing out use of the wrong word.


Anonymous said...

I would like you to blog on some ideas of what this means for Anna's estate. That is, questions such as, Is there anywhere for them to go from here? What sort of other actions might her estate take in light of this? And so on.

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