Church Joint Venture, L.P. v. Earl Blasingame, 986 F.3d 633

Earl and Margaret Blasingame hired Martin Grusin and Tommy Fullen to assist with a Chapter 7 filing; Fullen signed the petition filed Aug. 15, 2008.
The debtors’ schedules omitted millions in assets (trusts, companies, real estate, vehicles, bank accounts); Trustee pursued relief and the court eventually denied the Blasingames’ discharge.
The filing attorneys were later disqualified and both the Trustee (via creditor Church Joint Venture, L.P. with derivative standing) and the Blasingames sued the filing attorneys for legal malpractice alleging the attorneys’ negligence caused the discharge denial.
CJV sought a declaration that the malpractice claims were property of the bankruptcy estate; the Blasingames argued the claims were their post-petition property because damages (denial of discharge) arose after filing.
The bankruptcy court granted summary judgment to the Blasingames; the BAP affirmed, holding the malpractice claims accrued post-petition and belonged to the Blasingames; the Sixth Circuit affirmed.

Issue	Plaintiff's Argument (CJV)	Defendant's Argument (Blasingame)	Held
When did the malpractice claim accrue under state law?	Accrual occurred at or before filing because attorneys’ negligent acts happened pre-petition.	Accrual occurred post-petition because actual damage (denial of discharge) happened after filing.	Accrual occurred post-petition under Tennessee law; claim did not exist at commencement.
Does Segal’s “sufficiently rooted in the pre-bankruptcy past” make an unaccrued claim estate property?	Yes: pre-petition misconduct roots the claim in the past, so it becomes estate property.	No: unaccrued claims require awareness/actual legal interest at filing; post-petition damage controls.	Court rejected applying Segal to convert an unaccrued malpractice claim into estate property here.
Could the court split the malpractice claim into pre- and post-petition components?	Court should recognize and allocate pre-petition injury to the estate and post-petition injury to debtors.	No split necessary because the malpractice interest arose entirely post-petition.	No splitting required; the legal interest arose post-petition so it belongs to the debtors.

Segal v. Rochelle, 382 U.S. 375 (1966) (articulated "sufficiently rooted in the prebankruptcy past" test for estate property)
Butner v. United States, 440 U.S. 48 (1979) (property rights in bankruptcy are defined by state law absent a federal interest)
Tyler v. DH Capital Mgmt., Inc., 736 F.3d 455 (6th Cir. 2013) (discussed whether unaccrued claims can be estate property; set limits on "pre-petition" rooting)
Teeters v. Currey, 518 S.W.2d 512 (Tenn. 1974) (Tennessee accrual rule: cause of action accrues when injury is discovered)
Smith v. Tenn. Nat'l Guard, 551 S.W.3d 702 (Tenn. 2018) (reaffirmed Tennessee discovery/accrual rule and its application)
Ameraccount Club, Inc. v. Hill, 617 S.W.2d 876 (Tenn. 1981) (malpractice accrual when negligence becomes irremediable)
Witko v. Menotte (In re Witko), 374 F.3d 1040 (11th Cir. 2004) (held a legal-malpractice claim that harms post-petition is not estate property)