Siegel v. Fitzgerald, 596 U.S. 464

Congress created a United States Trustee Program (UST/Trustee Program) to handle bankruptcy administrative functions and funded it entirely via user fees deposited into the U.S. Trustee System Fund (UST Fund); six judicial districts in North Carolina and Alabama were allowed to opt out and remain in an Administrator Program funded by the Judiciary’s general budget.
Before 2018 the Judicial Conference generally matched Trustee Program fee changes in Administrator Program districts by standing order, producing uniform quarterly fees nationwide for similarly situated Chapter 11 debtors.
In 2017 Congress enacted a temporary, large increase in quarterly fees for Chapter 11 cases with large disbursements (effective Q1 2018 through 2022) to address a shortfall in the UST Fund; the increase applied immediately to pending and new cases in Trustee Program districts but was implemented later (Oct. 1, 2018) and only for newly filed cases in Administrator Program districts.
Circuit City’s Chapter 11 liquidation (filed 2008 in a Trustee Program district) remained open; its trustee (Siegel) paid ≈$632,542 in fees in the first three quarters of 2018—over $500,000 more than under the prior rate.
The Bankruptcy Court ruled the 2017 fee increase nonuniform and ordered pre-2017 rates applied from Jan. 1, 2018 onward; the Fourth Circuit reversed. The Supreme Court granted certiorari.

Issue	Plaintiff's Argument (Siegel)	Defendant's Argument (Fitzgerald/US Trustee)	Held
Whether the 2017 fee increase is a "law on the subject of bankruptcies" subject to the Bankruptcy Clause’s uniformity requirement	The fee amendment directly affects debtor-creditor relations and estate assets, so it is on the subject of bankruptcies and must be uniform	The fee is administrative/auxiliary and authorized by the Necessary and Proper Clause, not constrained by the Bankruptcy Clause uniformity rule	The Court: the 2017 Act is on the subject of bankruptcies; the uniformity requirement applies
Whether applying the fee increase to Trustee Program districts but not to the two Administrator Program States violated the uniformity requirement	Exempting only those two States was arbitrary and produced materially disparate treatment of similarly situated debtors	The disparity was a permissible response to a funding shortfall confined to the Trustee Program districts	The Court: the nonuniform increase violated the Bankruptcy Clause because Congress itself created the dual funding scheme and cannot treat identical debtors differently on that artificial basis
Proper remedy for the constitutional violation	Full refund of overpaid fees paid during the nonuniform period	Relief should be prospective only or equalize fees in Administrator Program districts; practical issues counsel against full refunds	The Court: remanded to the Fourth Circuit to decide remedy issues in the first instance

Moyses v. Hanover Nat'l Bank, 186 U.S. 181 (1902) (uniformity principle allows general uniform operation even if results vary by state)
Regional Rail Reorganization Act Cases, 419 U.S. 102 (1974) (Bankruptcy Clause permits geographically limited laws responding to geographically isolated problems)
Railway Labor Executives' Ass'n v. Gibbons, 455 U.S. 457 (1982) (Congress cannot evade Bankruptcy Clause uniformity by using other constitutional powers)
Wright v. Union Central Life Ins. Co., 304 U.S. 502 (1938) (the Bankruptcy Clause grants plenary power over the subject of bankruptcies)
Cutter v. Wilkinson, 544 U.S. 709 (2005) (courts of review should remand remedy questions to lower courts)
In re Circuit City Stores, Inc., 996 F.3d 156 (4th Cir. 2021) (Fourth Circuit decision below addressing the 2017 Act’s constitutionality)