Roy Arrieta v. Shannon Smith
Split Score
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Case Summary
Disposition
Reversed
The Eighth Circuit Bankruptcy Appellate Panel reversed the bankruptcy court’s order disallowing Roy Arrieta’s $400,000 tort claim against debtor Shannon Smith. The panel held that Arrieta’s assault- and battery-based allegations constitute a “personal injury tort” under 28 U.S.C. § 157(b)(5), so the bankruptcy court lacked authority to liquidate the claim and must allow the district court (and, if demanded, a jury) to try it. The case is remanded for further proceedings consistent with that ruling.
Circuit Split Identified
Legal Issue
Whether a proof of claim that is “deemed allowed” under 11 U.S.C. § 502(a) constitutes a final judgment that triggers res-judicata (claim-preclusion) effect in later litigation.
Circuit Positions
An allowed proof of claim is a final judgment for purposes of res judicata.
An allowed proof of claim is not automatically a final judgment; res judicata does not apply on that basis alone.
Issue is unresolved / expressly undecided; current opinion questions but does not adopt Ninth Circuit rule.
Conflict Summary
The Ninth Circuit treats an allowed proof of claim as the equivalent of a final judgment, so later suits between the same parties over the same transaction are barred by res judicata; the Fourth Circuit has expressly questioned and declined to follow that approach, concluding that an allowed claim does not automatically carry claim-preclusive effect. The present Eighth Circuit BAP opinion notes the disagreement, declines to adopt the Ninth Circuit rule, and leaves the question open for the Eighth Circuit.