In re Teresa Gail Baker v. DeKalb County, Georgia

United States Bankruptcy Court, E.D. Tennessee·Decided September 9, 2026·No. 1:26-ap-01005·Unknown

Opinion

□□ AE BANKROD> we * = oF Oy SIGNED this 9th day of September, 2026

[ected W Wats bury Nicholas W. Whittenburg UNITED STATES BANKRUPTCY JUDGE

IN THE UNITED STATES BANKRUPTCY COURT FOR THE EASTERN DISTRICT OF TENNESSEE SOUTHERN DIVISION

In re ) ) Teresa Gail Baker ) No. 1:15-10706-NWW ) Chapter 7 Debtor ) a”) ) Douglas R. Johnson, Trustee ) ) Plaintiff ) ) V. ) Adv. No. 1:26-ap-01005-NWW ) DeKalb County, Georgia ) ) ) Defendant )

MEMORANDUM The plaintiff, as chapter 7 trustee, filed a complaint initiating this adversary proceeding on March 16, 2026, seeking relief on a single count—inverse condemnation

against the defendant, DeKalb County, Georgia. The plaintiff alleges that the defen- dant’s longstanding and continued use of property of the estate as a landfill, without remediation, constitutes a taking under the Fifth Amendment to the United States Constitution. The plaintiff argues that the taking and the defendant’s unwillingness to allow a nonconforming lot division render the property unmarketable when it otherwise

would be worth millions of dollars. The defendant answered the complaint, denying the plaintiff's allegations and raising twenty-five affirmative defenses. The defendant preserved objections to this court’s subject matter jurisdiction over this proceeding, including whether the plaintiff's claim is core or non-core. The court held a scheduling conference on June 3, 2026, during which the defendant raised its jurisdictional concerns. Because jurisdiction and whether this proceeding is classified as core or non-core are threshold issues, the court ordered the parties to file briefs on those issues. See 28 U.S.C. § 157(b)(3).

With briefing now submitted, resolving the defendant's challenge to jurisdiction requires answering the following legal questions: 1) Does the court have subject matter jurisdiction over this adversary pro- ceeding pursuant to 28 U.S.C. § 1334(b)? 2) Is this a core or non-core proceeding pursuant to 28 U.S.C. § 157(b)? 3) If this is a core proceeding, does Article III preclude the court from enter- ing final judgment?

- 2 of 17 - Having considered the parties’ briefs, the court holds that it has subject matter jurisdiction over this adversary proceeding, that this is a core proceeding, and that Article III does not preclude the court from entering final judgment. I. Background

On February 20, 2015, Teresa Gail Baker filed a petition for relief under chapter 13 of the Bankruptcy Code. The day before a hearing on objections to confirmation of the debtor's proposed plan of reorganization, she converted the case voluntarily to one under chapter 7. On April 30, 2015, a chapter 7 trustee was appointed. Although over eleven years have passed since then, the debtor's bankruptcy case remains open due to unusual circumstances in administering part of the bankruptcy estate. The debtor's bankruptcy estate includes the debtor’s one-twelfth interest (either directly or indirectly as a member of Carmichael Concepts, LLC) in five unimproved real property lots located in DeKalb County, Georgia. Four of the five lots are contiguous,

totaling 14.62 acres, with the fifth lot being separated from the others by a railroad. Those four connected lots are at the center of this litigation. Only one of the four lots has access to a public road. The other three lots are landlocked. Beginning in 1955, the debtor’s grandfather leased land to the defendant for use as a landfill. The plaintiff contends that the entire landfill area consisting of approximately 11 acres, is spread out over three of the four contiguous lots, including a portion of the lot that provides access to a road. In 2016, the chapter 7 trustee commenced a separate adversary proceeding seeking authority under 11 U.S.C. § 363(h) to sell both the debtor’s one-twelfth interest - 3 of 17 - and also the co-owners’ eleven-twelfths interest in the DeKalb County lots. 1:16-ap-01029-NWW, ECF No. 1. Eight years later (on January 15, 2024), the trustee filed a settlement motion in the debtor’s bankruptcy case, seeking to approve a settlement between the parties to that adversary proceeding that would allow the trustee to market for sale the four lots.

Following responsive pleadings and a hearing, the court approved the settlement agreement. 1:15-bk-10706-NWW, ECF No. 189 (March 21, 2024 settlement order). That settlement order authorizes the trustee to market for sale the four connected lots free of the eleven-twelfths interest of the co-owners pursuant to 11 U.S.C. § 363(h). Id. at 7–8. The settlement order also states that “[t]he [t]rustee shall negotiate with the Georgia Department of Natural Resources, Environmental Protection Division, and/or DeKalb County, and/or any other governmental agency as he sees fit to resolve any issues (including, without limitation, subdivision, access and/or sale) regarding the landfill” located on the property. Id. at 8 (emphasis added).

Since 2016, the plaintiff has attempted to market and sell the properties he maintains are prime for development, absent the landfill. After years of speaking with developers and negotiating with the defendant, the plaintiff identified two ways to achieve a sale: 1) Either the defendant remediates the landfill portion of the properties, or 2) The defendant grants a subdivision variance that removes the landfill from the properties to be sold. The defendant's subdivision regulations require that parcels must front eighty- five feet on a public road—something made impossible by a landfill blocking the only - 4 of 17 - access to a road. The complaint alleges that the defendant's refusal to remediate the landfill coupled with its refusal to grant a subdivision variance amounts to a taking without just compensation because the defendant’s actions and inactions have made it impossible to develop and market the debtor’s interest in the properties, the bankruptcy estate’s most valuable asset. The plaintiff seeks just compensation for the defendant's

purported taking of the properties. II. Legal Analysis The bankruptcy court’s jurisdiction “is grounded in, and limited by, statute.” Celotex Corp. v. Edwards, 514 U.S. 300, 307 (1995). Section 1334(b) of title 28 gives district courts “original but not exclusive jurisdiction of all civil proceedings arising under title 11, or arising in or related to cases under title 11.” District courts may refer “any or all cases under title 11 and any or all proceedings arising under title 11 or arising in or related to a case under title 11 . . . to the bankruptcy judges for the district.” 28 U.S.C. § 157(a). The District Court for the Eastern District of Tennessee made such a

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