Background

• Louis Bullard filed Chapter 13 and proposed a multi‑amended repayment plan that split his mortgage into a secured portion (based on current value) and an unsecured deficiency to be partly discharged after the plan term.
• Blue Hills Bank objected to confirmation; the Bankruptcy Court denied confirmation, ruling the proposed split was not allowed but gave Bullard leave to amend.
• Bullard appealed to the First Circuit BAP; the BAP concluded the denial was not a "final" order but exercised discretionary interlocutory review and affirmed on the merits.
• Bullard sought review in the First Circuit, which dismissed for lack of jurisdiction because the underlying bankruptcy order denying confirmation was not final.
• The Supreme Court granted certiorari to decide whether an order denying confirmation of a Chapter 13 plan (with leave to amend) is a final, immediately appealable order.

Issues

Key Cases Cited

• Howard Delivery Service, Inc. v. Zurich American Ins. Co., 547 U.S. 651 (2006) (orders in bankruptcy may be immediately appealed if they finally dispose of discrete disputes)
• Mohawk Industries, Inc. v. Carpenter, 558 U.S. 100 (2009) (piecemeal appeals undermine efficient judicial administration)
• United Student Aid Funds, Inc. v. Espinosa, 559 U.S. 260 (2010) (confirmation orders are enforceable and binding despite some legal error)
• Digital Equipment Corp. v. Desktop Direct, Inc., 511 U.S. 863 (1994) (some burdensome rulings are only imperfectly reparable on appeal)
• Swint v. Chambers County Comm’n, 514 U.S. 35 (1995) (final decision definition and district court disassociation from case)
• Firestone Tire & Rubber Co. v. Risjord, 449 U.S. 368 (1981) (finality and efficient judicial administration)