Bankruptcy: Secured Creditors Court Jurisdiction, Procedure and Review: Federal Court Jurisdiction

摘要

As part of the SemGroup bankruptcy proceeding, Plains Marketing tenders $2.5 million to the debtors, subject to a number of conditions and reservations, including a reservation of rights with respect to Samson's claims against Plains Marketing. Samson then files a number of state court actions seeking declaratory judgments that Plains Marketing is a first purchaser from Samson and thus, the resulting proceeds are encumbered by various state-created security interests and/or liens. The cases are removed to federal court and shortly thereafter, the Delaware Bankruptcy Court approves the debtors' joint plan of reorganization. The joint plan recognizes that Plains Marketing can continue to assert its claims, if any, against the debtors. Plains files a motion with the bankruptcy court to recoup a portion of the tendered funds, which is opposed by the debtors. Samson then files a motion to remand this case back to the New Mexico state court systems, but at a hearing, the district court judge raises the issue of whether it has jurisdiction over the case. Federal court jurisdiction over bankruptcy matters is denned by statute (28 U.S.C. § 1334). The jurisdictional grant of power to district courts to deal with bankruptcy matters depends on whether "core" or "non-core" proceedings are involved. The nature of the action brought by Samson is that Plains is in wrongful possession of oil and the proceeds from the sale of that oil, which are subject to Samson's security interests. That type of declaratory relief is a core bankruptcy proceeding because it involves whether or not certain assets are part of, or outside of, the bankruptcy estate. Thus, the district court judge, having jurisdiction over the parties and subject matter, refers the case to the United States Bankruptcy Court for the District of New Mexico.