Howard Delivery Services, Inc. (Howard) (defendant) was a freight-trucking business that operated in several states. Each state required Howard to obtain workers’ compensation coverage for Howard’s employees. Howard hired Zurich American Insurance Company (Zurich) (plaintiff) as a workers’ compensation provider. Howard eventually filed for bankruptcy under the United States Bankruptcy Code (Bankruptcy Code). Zurich filed an unsecured creditor’s claim for $400,000 in unpaid workers’ compensation premiums. Zurich sought priority status under section 507(a)(5) of the Bankruptcy Code, 11 U.S.C. § 507(a)(5). The bankruptcy court denied priority status to Zurich’s claim, and the federal district court affirmed. The court of appeals reversed. The United States Supreme Court granted certiorari.