Friday, September 11, 2026

Waivers Must Be Knowing, Voluntary and Intelligent

Ever since Stern v. Marshall, bankruptcy lawyers are frequently asked to consent to entry of final orders by the Bankruptcy Court. I routinely agree to consent because the Bankruptcy Court is a familiar forum and the judges are a known quantity. Occasionally I will say no for strategic reasons. While we deal with these issues on a routine basis, the Fifth Circuit has reminded us that waiving a right to trial before an Article III Judge is a big deal.

A new Fifth Circuit case dealing with consent to trial by a Magistrate Judge might be useful if parties find that they have improvidently consented to entry of final orders by the Bankruptcy Court. In Case No. 24-30552, IFG Port Holdings, LLC v. Lake Charles Harbor & Terminal District, a losing party got a do-ever when it turned out that the Magistrate Judge failed to disclose her close relationship with opposing counsel. While this is not a bankruptcy case, it could be useful to bankruptcy litigants.