The High Court Report

Opinion Summary: United States v. Miller | Date Decided: 3/26/25 | Case No. 23-824


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Case Info: United States v. Miller | Date Decided: 3/26/25 | Case No. 23-824

Link to Docket: Here.

Question Presented: Whether a bankruptcy trustee may avoid a debtor's tax payment to the United States under Section 544(b) when no actual creditor could have obtained relief under the applicable state  fraudulent-transfer law outside of bankruptcy.

Holding: Section 106(a)’s sovereign-immunity waiver applies only to a §544(b) claim itself and not to state-law claims nested within that fed­eral claim.

Result: Reversed.

Voting Breakdown: Justice Jackson delivered the opinion of the Court, joined by Chief Justice Roberts, along with Justices Thomas, Alito, Sotomayor, Kagan, Kavanaugh and Barrett.  Justice Gorsuch filed a dissenting opinion.

Link to Opinion: Here.

Oral Advocates:

  • For petitioner: Yaira Dubin, Assistant to the Solicitor General, Department of Justice, Washington, D. C.
  • For respondent: Lisa S. Blatt, Washington, D. C.

Website Link to Oral Argument: Here.

Apple Podcast Link to Oral Argument: Here.

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