United States v. Miller
In brief
Bankruptcy trustees cannot use the Bankruptcy Code's immunity waiver to bring state-law transfer claims against the United States that private creditors could not bring themselves.
- Where it stands
- Decided
Decided 8-1 · March 26, 2025 · Opinion by Justice Jackson
- What it’s about
- The Supreme Court held that while the Bankruptcy Code waives the federal government's sovereign immunity for certain claims, this waiver does not extend to state-law fraudulent transfer claims that a trustee attempts to bring against the IRS, because a private creditor could not have sued the government under state law outside of bankruptcy.
- Who it affects
- Trustees cannot recover a debtor's tax payment from the IRS through this route when the government would be protected from the same state-law lawsuit outside bankruptcy. That limits potential recoveries for bankruptcy estates and creditors.
Summary: written with AI from the case record.
What it's about
The case defines how far Congress's waiver of the federal government's immunity from lawsuits reaches in bankruptcy cases.
Question presented
May a bankruptcy trustee avoid a debtor’s tax payment to the United States under 11 U.S.C. § 544(b) when no actual creditor could have obtained relief under the applicable state fraudulent-transfer law outside of bankruptcy?
What the Court decided
Holding
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. 71 F. 4th 1247, reversed.
- Result
- Reversed
The vote
From the opinions
““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.””
What's next
Lower courts must apply the Court's ruling in similar bankruptcy disputes involving tax payments to the federal government. Trustees and creditors will need to assess other available ways to challenge or recover transfers.
Documents
Docket activity
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More questions
- What did the Supreme Court rule in United States v. Miller?
- The Court said trustees cannot use Section 544(b) to sue the IRS under state law when private creditors could not sue the government outside bankruptcy.
- Who is affected by the Miller decision?
- Bankruptcy trustees, creditors, debtors, and the IRS are affected. Trustees have a narrower path to seek recovery of tax payments for bankruptcy estates.
- What happens next after United States v. Miller?
- Lower courts will follow the ruling in similar cases. Trustees must evaluate whether another legal basis supports a claim involving a tax payment.
Sources
Primary materials plus reporting. Best-effort analysis: this explainer relies on a mix of primary materials and trusted secondary sources. Official filings and opinions remain authoritative.