Randy Netzer v. Office of Lawyer Regulation, 2017 U.S. App. LEXIS 4396

Debtor Randy Netzer sought bankruptcy discharge of roughly $9,200 in costs imposed by the Wisconsin Supreme Court in a lawyer-discipline proceeding.
The bankruptcy court held the sanction was a “fine, penalty, or forfeiture” under 11 U.S.C. § 523(a)(7) and nondischargeable. (Bankr. W.D. Wis. Feb. 3, 2016)
Netzer filed a notice of appeal 41 days after the bankruptcy decision; the 14-day appeal period in Fed. R. Bankr. P. 8002(a)(1) had expired.
Netzer asked the district court to excuse the late filing, claiming he had not known of the bankruptcy decision earlier; the district court dismissed the appeal as untimely.
The district court treated the 14-day rule as jurisdictional (following In re Sobczak-Slomczewski) and noted federal rules (Bankr. R. 9022(a) and 8002(d)(1)) limit extensions: a bankruptcy judge may extend time if requested within 35 days.
The court emphasized that equitable tolling cannot override bankruptcy statutes and rules; lack of notice does not create additional equitable relief beyond Rule 8002's procedures.

Issue	Netzer's Argument	Opponent's Argument	Held
Whether the Supreme Court of Wisconsin’s costs are dischargeable under §523(a)(7)	Costs are dischargeable in bankruptcy	Costs are a “fine, penalty, or forfeiture” and nondischargeable	Bankruptcy court held costs nondischargeable; affirmed as to procedural posture here
Whether the district court could excuse Netzer’s late appeal on equitable grounds	Equitable excuse for tardy appeal due to lack of knowledge	14-day appellate rule is binding; only Rule 8002 permits limited extensions	Court enforced the rule: equitable relief not available; extensions limited to Rule 8002(d) and must be sought in time

Bowles v. Russell, 551 U.S. 205 (construes strict limits on appellate-timing rules and rejects equitable exceptions)
Kontrick v. Ryan, 540 U.S. 443 (treats certain procedural time limits as nonjurisdictional)
Eberhart v. United States, 546 U.S. 12 (appellate timing rule held nonjurisdictional in criminal context)
Law v. Siegel, 571 U.S. 415 (courts lack equitable power to contravene bankruptcy statutes)
In re Sobczak-Slomczewski, 826 F.3d 429 (7th Cir. 2016) (treats Rule 8002(a)(1) 14-day period as jurisdictional)
In re Kmart Corp., 359 F.3d 866 (7th Cir. 2004) (limits on equitable relief in bankruptcy context)
United States v. Neff, 598 F.3d 320 (7th Cir. 2010) (discussion of appellate timing rules and jurisdiction)

AFFIRMED