Springer v. United States
- Summarized by Jonathan Batiste , Rensselaer Polytechnic Institute
- 6 months 3 days ago
- Case Type:
- Consumer
- Case Status:
- Affirmed
- Citation:
- No. 24-5109 (10th Circuit, Aug 21,2025) Published
- Tag(s):
-
- Ruling:
- The circuit court affirmed the district court’s decision, affirming the bankruptcy court’s denial of Debtor’s motion to reopen his bankruptcy case. Debtor’s opening brief did not challenge the bankruptcy court’s ruling that claim preclusion prevented him from pursuing arguments in adversary proceedings. Debtor therefore waived any challenge to the court’s ruling; the bankruptcy court did not abuse its discretion by denying Debtor’s motion to reopen. Failure to address issues in opening briefs functions to waive any challenges.
- Procedural context:
- Debtor petitioned the United States Tax Court for relief from tax liabilities he accrued. The court dismissed Debtor’s petition as frivolous, and Debtor appealed the decision to the circuit court. The circuit court dismissed Debtor’s appeal. Debtor then filed a bankruptcy petition, seeking to discharge the accrued tax debts. The bankruptcy granted the discharge, but excluded the tax debts from the discharge. Debtor then moved to reopen the bankruptcy case after the government continued its collection efforts. The bankruptcy court denied Debtor's motion, and he appealed to the district court. The district court affirmed the bankruptcy court’s decision, and Debtor appealed to the circuit court.
- Facts:
- Lindsey Kent Springer (“Debtor”) failed to pay federal income taxes from 1990 to 1995. The IRS assessed Debtor’s tax liabilities, and he petitioned for relief in the United States Tax Court. The court dismissed his petition as frivolous, and it adjudicated tax liabilities in 1997. Debtor appealed that decision to the circuit court, but the court denied his appeal because he had not paid monetary sanctions imposed in a previous frivolous appeal. The Tax Court and the district court concluded that the Tax Court’s 1997 judgment had claim preclusive effect and barred Debtor from challenging the Tax Court's decision regarding the tax debts. Debtor then, in an effort to shed the tax debts, filed for bankruptcy in 2022. The bankruptcy court granted a discharge, but excluded the tax debts from the discharge. Debtor then moved to reopen the case after the IRS continued its efforts to collect his debts. The bankruptcy court denied his motion as claim preclusion barred him from challenging the Tax Court’s 1997 decision. Debtor appealed to the district court, which affirmed the bankruptcy court’s decision. Debtor then appealed again to the circuit court. Debtor argued that the IRS violated the discharge order by continuing its collection efforts, and he sought to file an adversary complaint to obtain relief. The circuit court decided against Debtor because he failed to challenge the bankruptcy court’s ruling in his opening brief. As Debtor waived any challenge to the bankruptcy court’s ruling, the circuit court concluded that the bankruptcy court did not abuse its discretion by denying Debtor’s motion.
- Judge(s):
- Hartz, Moritz, and Rossman
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