Johns Manville Corporation v. United States, 24-402

Plaintiffs, including Acadiana Management Group and Johns Manville Corp., sought refunds of increased Chapter 11 bankruptcy quarterly fees, alleging those fees violated the Bankruptcy Clause’s uniformity requirement.
The fee increase, authorized by the 2017 Act, created a temporary disparity between U.S. Trustee districts and Bankruptcy Administrator districts until Congress equalized fees in 2021.
The Supreme Court ruled in Siegel v. Fitzgerald (2022) that the nonuniform fee structure violated the Constitution but reserved the remedy question, later holding in Hammons (2024) that only prospective parity was required as a remedy.
Plaintiffs brought refund claims in the Court of Federal Claims via an illegal exaction theory under the Tucker Act, arguing they were unlawfully charged higher fees.
The government moved to dismiss, contending Hammons precluded any refund remedy for the constitutional violation.
Both cases were consolidated, and the court was asked to decide if the Tucker Act provided a viable refund remedy despite the Supreme Court’s ruling.

Issue	Plaintiff's Argument	Defendant's Argument	Held
Does the Bankruptcy Clause violation entitle Plaintiffs to a refund under the Tucker Act?	Refund is warranted because fees were collected unconstitutionally.	Hammons holds prospective parity is the only remedy.	No refund required; claim dismissed.
Does the Hammons decision foreclose Tucker Act claims for refunds?	Hammons addressed bankruptcy, not illegal exaction claims here.	Hammons forecloses any refund remedy, including via Tucker Act.	Hammons forecloses this remedy.
Can Plaintiffs raise new legal or factual arguments not considered by Hammons?	Hammons was incomplete; lower court can consider new arguments.	Lower courts bound by Supreme Court’s reasoning, regardless of omissions.	Bound by Hammons; court cannot revisit.
Should class certification be granted for similarly situated debtors?	Class certification is appropriate if claim viable.	Moot because claims fail as a matter of law.	Denied as moot.

Siegel v. Fitzgerald, 596 U.S. 464 (2022) (declared the nonuniform bankruptcy fees unconstitutional, but reserved the remedy question)
Off. of U.S. Tr. v. John Q. Hammons Fall 2006, LLC, 602 U.S. 487 (2024) (held that prospective fee parity is the appropriate remedy for nonuniform bankruptcy fees)
Swann v. Charlotte-Mecklenburg Bd. of Educ., 402 U.S. 1 (1971) (scope of remedy determined by nature of violation)
Boeing Co. v. United States, 968 F.3d 1371 (Fed. Cir. 2020) (Tucker Act illegal exaction claim requirements)
Christy, Inc. v. United States, 971 F.3d 1332 (Fed. Cir. 2020) (definition of illegal exaction)