Jonathan S. Metcalf v. Michael Fitzgerald et al.

Summary

The Connecticut Supreme Court affirmed dismissal of state-law vexatious litigation and Connecticut Unfair Trade Practices Act claims arising from conduct during a bankruptcy proceeding. The court held that federal bankruptcy law implicitly preempts those claims because Congress occupied the field of penalties and sanctions for abuse of the bankruptcy process and because state-law remedies could undermine the uniformity and finality of bankruptcy proceedings.

Holdings

1. The Bankruptcy Code does not expressly preempt the plaintiff's state-law CUTPA and vexatious litigation claims because it contains no provision explicitly precluding those causes of action.
2. The Bankruptcy Code impliedly preempts state-law CUTPA and vexatious litigation claims based on alleged abuse of the bankruptcy process because Congress occupied the field of penalties and sanctions for such abuse.
3. Although compliance with the Bankruptcy Code and Connecticut law would not be impossible, the state-law CUTPA and vexatious litigation claims are conflict-preempted because they obstruct Congress's objectives of uniformly defining the scope and availability of remedies for abuse of the bankruptcy process.

Questions Presented

1. Whether the Bankruptcy Code expressly preempts state-law vexatious litigation and CUTPA claims arising from alleged abuse of the bankruptcy process.
2. Whether the Bankruptcy Code implicitly preempts those state-law claims by occupying the field of penalties and sanctions for abuse of the bankruptcy process.
3. Whether the state-law claims are conflict-preempted because they obstruct Congress's objectives of uniformity and finality in the bankruptcy system.
4. Whether the Connecticut Supreme Court should decline to follow or overrule Lewis v. Chelsea G.C.A. Realty Partnership, L.P.

Disposition

affirmed