Wellness International Network, Ltd. v. Sharif

Summary

The Supreme Court held that Article III permits bankruptcy judges to adjudicate claims otherwise requiring an Article III court when the parties knowingly and voluntarily consent. Consent need not be express and may be inferred from the parties’ actions, but it must be knowing and voluntary. The Court reversed and remanded for the Seventh Circuit to determine whether Sharif consented to bankruptcy-court adjudication or forfeited his constitutional objection.

Holdings

1. Article III permits a bankruptcy judge to adjudicate a Stern claim when the parties knowingly and voluntarily consent to that adjudication.
2. Consent to bankruptcy-court adjudication of a Stern claim need not be express; it may be implied from the parties' actions, but it must be knowing and voluntary.
3. The Seventh Circuit should decide on remand whether Sharif's actions demonstrated knowing and voluntary consent and whether he forfeited his Stern argument.

Questions Presented

1. Whether Article III permits a bankruptcy judge to adjudicate a Stern claim when the parties knowingly and voluntarily consent.
2. Whether consent to bankruptcy-court adjudication must be express or may be implied from the parties' conduct.
3. Whether the Seventh Circuit should determine on remand whether Sharif knowingly and voluntarily consented to bankruptcy-court adjudication and whether he forfeited his Stern objection.

Disposition

reversed_and_remanded