In Re Microage Corp.

288 B.R. 842, 2003 Bankr. LEXIS 73, 40 Bankr. Ct. Dec. (CRR) 222, 2003 WL 255945
CourtUnited States Bankruptcy Court, D. Arizona
DecidedJanuary 7, 2003
DocketBR-00-03833, BR-00-03840-ECF-CGC to BR-00-03850-ECF-CGC
StatusPublished
Cited by2 cases

This text of 288 B.R. 842 (In Re Microage Corp.) is published on Counsel Stack Legal Research, covering United States Bankruptcy Court, D. Arizona primary law. Counsel Stack provides free access to over 12 million legal documents including statutes, case law, regulations, and constitutions.

Bluebook
In Re Microage Corp., 288 B.R. 842, 2003 Bankr. LEXIS 73, 40 Bankr. Ct. Dec. (CRR) 222, 2003 WL 255945 (Ark. 2003).

Opinion

UNDER ADVISEMENT MEMORANDUM DECISION RE: DEBTORS’ OBJECTION TO CLAIMS OF ARIZONA DEP’T OF REVENUE AND MOTION FOR DETERMINATION OF DEBTORS’ RIGHT TO TAX REFUND

CHARLES G. CASE, II, Bankruptcy Judge.

I. The Issue

This case squarely presents whether this Court can constitutionally require the State of Arizona (“State”) to litigate Debt- or’s entitlement to a disputed tax refund in bankruptcy court or whether it is immune from such proceeding. The following issues have been addressed by the parties: 1) whether the States ceded sovereign immunity to the federal government under the “plan” of the Constitutional Convention; 2) whether 11 U.S.C. section 106(a)’s waiver of the State’s immunity is constitutional; 3) whether the State has waived sovereign immunity in this proceeding, either through its participation in the case or pursuant to 11 U.S.C. section 106(b); 4) whether the State has waived immunity to the extent of any set off rights Debtor may have; and 5) whether the State of Arizona has abrogated sovereign immunity in cases pending in federal court. 1

II. Background

The Arizona Department of Revenue (“ADOR”) filed five Proofs of Claim against various affiliated Debtor entities, all of which have apparently been resolved between the parties. In particular, the ADOR filed four Proofs of Claim for transaction privilege taxes (“TPT”), three of which the ADOR estimated at $75,000 each and one that was stated at $2,737.93. The ADOR also filed a Proof of Claim for corporate income taxes of $57.90. Debtors filed an omnibus objection to the three $75,000 TPT claims, requesting that the three claims be allowed in the amounts of $12,000.00, $96,000.00, and $164,000.00 respectively. The ADOR did not respond, thereby agreeing to these amounts. Debtors also objected to the two remaining Proofs of Claims to which the ADOR never responded: The two claims were therefore disallowed. 2

Subsequently, Debtors filed this Motion for Determination of Debtors’ Right to Tax Refund. Debtors allege that they are entitled to an $870,573 tax refund as a result of changes to Arizona’s enterprise zone employment tax credit program codified at Arizona Revised Statute (“A.R.S.”) section 43-1161 et. seq. 3 On the merits, the ADOR contends that Debtors are entitled to a tax refund of only $172,937 plus applicable interest. Before the merits of the *845 claim can be addressed, however, the Court must address the ADOR’s argument that the State is immune from this proceeding under the Eleventh Amendment to the United States Constitution.

III. Analysis

A. Applicability of Eleventh Amendment Sovereign Immunity in Bankruptcy

Following the United States Supreme Court’s decision in Chisholm v. Georgia in 1793, 4 alarm among the States about the continuing vitality of their immunity from suit in federal court led to the ratification of the Eleventh Amendment. 5 It is well established that the Eleventh Amendment neither created nor expanded States’ immunity from suit in federal court but rather preserved it to the extent it existed after the adoption of the Constitution. 6 Although numerous cases have assumed that states’ immunity in bankruptcy cases survived the adoption of the Constitution, neither the Supreme Court nor any Court of Appeals has yet explicitly addressed that issue. Debtors therefore posit that the Eleventh Amendment is inapplicable here because the States ceded their authority over cases arising under the bankruptcy power to the federal government through the adoption of Article 1, Section 8. 7 Under Debtor’s theory, the subsequent adoption of the Eleventh Amendment did not restore immunity in bankruptcy cases to the States; rather, the pre Chisholm status quo preserved by the Eleventh Amendment includes the ceding of immunity over this narrow category of cases. 8

To determine the structure of the original Constitution, the United States Supreme Court routinely relies upon the Federalist Papers. Federalist No. 32 states that the federal government may exercise exclusive jurisdiction in three situations: 1. “where the Constitution in express terms granted an exclusive authority to the Union”; 2. where the Constitution “granted in one instance an authority to the Union and in another prohibited the States from exercising the like authority”; and 3. where the Constitution “granted an authority to the Union, to which a similar authority in the States would be absolutely and totally contradictory and repugnant.” The Federalist No. 32 at 152-53.

*846 There is little dispute that Article 1, Section 8 prevents States from legislating in the bankruptcy arena, a conclusion that makes perfect sense. As was discussed in the Federalist No. 32, exclusive authority to legislate some areas of the law must lie with the federal government to establish a uniform rule of law, such as in the area of naturalization, “because if each state had power to prescribe a DISTINCT RULE there could be no UNIFORM RULE.” Id. (emphasis in original). However, immunity from suit is quite a different matter. While Federalist No. 81 does explicitly state that the naturalization power rests exclusively with the union because “a similar authority in the states would be absolutely and totally contradictory and repugnant,” (emphasis in original) it does not suggest that States could be sued in federal court monetary damages arising out of “naturalization” claims. 9 Nevertheless, Debtors argue that because the naturalization power and bankruptcy power each derive from the same sentence of Article I, Section 8, uniformity in bankruptcy and naturalization necessarily implies a full waiver of sovereign immunity.

Even if Hamilton intended in Federalist No. 81 that states could be sued for “naturalization” claims, the difficulty is that naturalization is not comparable to bankruptcy. Bankruptcy necessarily involves the adjustment of debtor obligations and creditor rights, and a State is often a creditor. The Creditors in bankruptcy cases face both adjustment of the debts owed them and collection of debts they owe debtors. Hamilton’s gut-level aversion to the forced collection in federal court of debts from states is also clearly stated in Federalist No. 81:

The contracts between a nation and individuals are only binding on the conscience of the sovereign, and have no pretensions to a compulsive force. They confer no right of action, independent of the sovereign will.

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Bluebook (online)
288 B.R. 842, 2003 Bankr. LEXIS 73, 40 Bankr. Ct. Dec. (CRR) 222, 2003 WL 255945, Counsel Stack Legal Research, https://law.counselstack.com/opinion/in-re-microage-corp-arb-2003.