Matthew Jenkins v. James Ward, Sr., 784 F.3d 230

Background

Matthew Jenkins filed a pro se Chapter 7 petition and disclosed substantial pre-petition lawsuit proceeds but not their current status.
At the §341 creditors’ meeting the Trustee learned the proceeds were in the wife’s account and Jenkins had access; Trustee sought extra time to pursue information and the bankruptcy court extended the deadline for objecting to discharge to “60 days beyond whenever the 341 meeting is concluded.”
The creditors’ meeting reconvened by phone on July 19, 2012; Trustee’s counsel announced the meeting was “continued” but did not announce an adjourned date/time and did not promptly file any statement specifying an adjourned date as required by Fed. R. Bankr. P. 2003(e).
The Trustee never reconvened the meeting or otherwise complied with Rule 2003(e); 69 days after July 19 the Trustee filed a §727 complaint objecting to Jenkins’s discharge.
Bankruptcy court granted summary judgment denying discharge as timely; district court affirmed; Fourth Circuit reviews legal conclusions de novo and reverses, holding Trustee’s complaint untimely because the creditors’ meeting had concluded on July 19.

Issues

Issue	Plaintiff's Argument	Defendant's Argument	Held
When did the §341 creditors’ meeting "conclude" for purposes of the extended 60-day deadline under Rule 4004?	Jenkins: meeting concluded July 19 because no adjourned date/time was announced as required by Rule 2003(e).	Trustee: clock runs from when parties received notice the meeting had concluded; meeting was continued and not concluded (could be later docket entries or reconvening).	Held: meeting concluded July 19; trustee failed to comply with Rule 2003(e), so the 60-day period began then and Trustee’s complaint was untimely.
Whether a trustee can effectively adjourn a meeting sine die (no date set) after 2011 amendment to Rule 2003(e)	Jenkins: 2011 amendment requires presiding official to promptly file adjournment date/time; prevents indefinite adjournment; failure means meeting concluded.	Trustee: court should apply a case-by-case reasonableness inquiry (Peres factors) to judge delay in continuing reconvening.	Held: 2011 amendment prohibits indefinite adjournment; Peres-style balancing inappropriate here; adjournment without compliance with Rule 2003(e) does not prevent conclusion on last convened date.
Whether courts must apply a per se bright-line rule (automatic conclusion if adjournment procedures not followed)	Jenkins: failure to comply with Rule 2003(e) should per se conclude the meeting.	Trustee: bright-line rule is too rigid; equitable exceptions and substantial compliance may apply.	Held: Court declines to adopt a universal bright-line rule but enforces Rule 2003(e) here — failure to comply and no substantial steps taken meant the meeting concluded on July 19.
Whether the automatic grant of discharge under Rule 4004(c)(1) can be avoided despite untimely objection	Jenkins: untimely objection bars denial; discharge must be granted.	Trustee: court should be able to deny discharge despite untimeliness, citing equitable concerns.	Held: Rule 4004(c)(1) and the Code require grant of discharge once the objection period expires; exceptions are limited and not argued here.

Key Cases Cited

Kontrick v. Ryan, 540 U.S. 443 (explaining discharge effect and importance of procedural rules in bankruptcy)
Law v. Siegel, 134 S. Ct. 1188 (discussing limits on bankruptcy courts’ equitable powers and denying dishonest debtors discharge)
Taylor v. Freeland & Kronz, 503 U.S. 638 (emphasizing finality from strict adherence to procedural deadlines in bankruptcy)
In re Peres, 530 F.3d 375 (5th Cir.) (pre-2011 case using a case-by-case four-factor test on whether a creditors’ meeting adjourned sine die is "concluded")
In re Smith, 235 F.3d 472 (9th Cir.) (holding meeting concluded unless adjourned to a stated date/time)
In re Nieves, 648 F.3d 232 (4th Cir.) (standard of review for bankruptcy appeals)