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LANGENKAMP – Appellant
Versus
CULP, (1990) – Respondent


United States Supreme Court
LANGENKAMP v. CULP, (1990)
No. 90-93
Decided On : November 13, 1990

Respondents held thrift and passbook savings certificates, which were issued by debtor financial institutions and represented debtors promise to repay moneys respondents had invested. Within the 90-day period before debtors filed Chapter 11 bankruptcy petitions, respondents redeemed some of the certificates. They became debtors creditors when they filed proofs of claims against the bankruptcy estates. Subsequently, petitioner trustee instituted adversary proceedings to recover, as avoidable preferences, the payments which respondents had received. After a bench trial, the Bankruptcy Court ruled that the payments were avoidable preferences, and the District Court affirmed. The Court of Appeals, relying on Grandfinanciera, S.A. v. Nordberg, 492 U.S. 33, and Katchen v. Landy, 382 U.S. 323, reversed, ruling that respondents were entitled to a jury trial in the preference action.

Held:

Respondents were not entitled to a jury trial. By filing claims against the bankruptcy estate, respondents triggered the process of "allowance and disallowance of claims," thereby subjecting the

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