News & Analysis as of

Barton Doctrine Court-Appointed Receivers

Ervin Cohen & Jessup LLP

The Exception to the Barton Doctrine Contained in 28 U.S.C. §959(a) Does Not Apply to State Court Receivers

Q: I am a state court receiver for an LLC that owns a number of apartment buildings, which I am now managing. I have been sued by some tenants and a tenant group. They have not obtained receivership court permission to sue...more

Ervin Cohen & Jessup LLP

The Ultra Vires Exception to the Barton Doctrine is Very Narrow

Q: I am a state court receiver in a case that has been disrupted by a bankruptcy filing. The bankruptcy trustee has been threatening to sue me, in the bankruptcy court, for what she claims were negligent actions and to...more

Ervin Cohen & Jessup LLP

Is a receiver’s property manager protected by the Barton Doctrine and quasi-judicial immunity

Q: I was appointed receiver over a manufacturing facility. I operated it for a short time and then obtained court authority to sell it. I netted $1.4 million from the sale....more

Buchalter

Bankruptcy Trustees and Receivers Beware: The California Second District Court of Appeal Tests The Barton Doctrine’s Limits on...

Buchalter on

In Breanne Martin v. Leslie Gladstone, the Second District Court of Appeal recently decided a case that could reverberate throughout the receivership and bankruptcy industries. This case comes at a propitious moment as...more

Jones Day

Fifth Circuit: Barton Doctrine Precluded Litigation by Chapter 7 Debtor Against Bankruptcy Trustee and Counsel

Jones Day on

To shield bankruptcy trustees and certain other entities from litigation arising from actions taken in their official capacity, the "Barton doctrine"—now more than a century old—provides that such litigation may be commenced...more

Rosenberg Martin Greenberg LLP

Abstention Trumps the Barton Doctrine in the Fourth Circuit

In Barton v. Barbour, the United States Supreme Court held that before another court could obtain subject matter jurisdiction over a suit against a receiver for acts committed in the receiver’s official capacity, the...more

Ervin Cohen & Jessup LLP

Can a Discharged Receiver Be Sued Without Court Permission?

Q:  I was discharged as receiver a number of years ago. One of the defendants in the case has now sued me and my former attorney, contending we violated his civil rights when I sold some of his assets and that we conspired...more

Jones Day

Stay Extended to Bar Litigation Against Chapter 15 Foreign Representatives but No Ruling on Extraterritoriality of Barton Doctrine

Jones Day on

In McKillen v. Wallace (In re Irish Bank Resolution Corp. Ltd.), 2019 WL 4740249 (D. Del. Sept. 27, 2019), the U.S. District Court for the District of Delaware had an opportunity to consider, as an apparent matter of first...more

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