Metcalf v. FitzgeraldAnnotate this Case
The Supreme Court affirmed the judgment of the trial court granting motions to dismiss Plaintiff's state law claims for vexatious litigation and unfair and deceptive business acts or practices during Plaintiff's underlying bankruptcy proceeding, holding that the trial court properly dismissed the claims for lack of subject matter jurisdiction because the claims were preempted by federal bankruptcy law.
Plaintiff, who had previously filed a bankruptcy petition in the United States Bankruptcy Court, brought this action asserting claims of vexatious litigation and violation of the Connecticut Unfair Trade Practices Act, Conn. Gen. Stat. 42-110a et seq. The trial court dismissed the claims. The Supreme Court affirmed, holding that Congress implicitly preempted state law actions by occupying the field of bankruptcy law and that, in the field of law, the federal interest is so dominant that federal law is assumed to preclude enforcement of state laws on the subject.