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Citizens Bank of Maryland v. Strumpf
United States Supreme Court
516 U.S. 16 (1995)
On January 25, 1991, the date on which he filed a Chapter 13 bankruptcy petition, Strumpf (defendant) held a checking account with Citizens Bank of Maryland (Citizens) (plaintiff) and was in default to Citizens on a $5,068.75 loan. Strumpf’s petition triggered an automatic stay of certain creditor activity, including any setoff of prebankruptcy debt. In October 1991, Citizens placed an administrative hold on Strumpf’s account, blocking any withdrawals that would reduce the balance to less than Strumpf’s debt to Citizens. Five days later, Citizens moved the bankruptcy court for relief from the automatic stay so that the bank could debit Strumpf’s account to offset the loan debt. Strumpf responded with a motion to hold Citizens in contempt on the grounds that its administrative hold violated the automatic stay. The bankruptcy court considered Strumpf’s motion first, ruling in his favor that the hold was a setoff prohibited by the stay. The court sanctioned Citizens. Several weeks later, the court considered and granted Citizens’ motion for relief from the stay. By that point, however, Strumpf had drained the account. The district court reversed the bankruptcy court’s determination that Citizens violated the stay. The court of appeals then reversed the district court. Citizens petitioned the Supreme Court for certiorari.
Rule of Law
Holding and Reasoning (Scalia, J.)
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