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 may be express or implied, but the Seventh Circuit was required on remand to determine whether Sharif’s conduct demonstrated the requisite consent and whether he forfeited his constitutional objection. The Court reversed and remanded the Seventh Circuit’s judgment.

Holdings

1. Article III permits bankruptcy judges to adjudicate Stern claims when the parties knowingly and voluntarily consent.
2. Consent under 28 U.S.C. § 157(c)(2) need not be express; it may be implied from the parties' actions, but it must be knowing and voluntary.
3. The Seventh Circuit must determine 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 Sharif knowingly and voluntarily consented to adjudication by the Bankruptcy Court and whether he forfeited his Stern objection.

Disposition

reversed_and_remanded