Waldron v. FDIC, No. 18-35375 (9th Cir. 2019)Annotate this Case
The Ninth Circuit reversed the district court's judgment affirming the bankruptcy court's judgment in favor of the chapter 7 trustee. The trustee claimed that the tax refunds should be considered part of the bankruptcy estate and the bankruptcy court agreed. However, the panel held that the trustee failed to exhaust the administrative claims process as required by the Financial Institutions Reform, Recovery, and Enforcement Act of 1989. Therefore, the panel held that the bankruptcy court did not have subject matter jurisdiction over the dispute because of the failure to exhaust.