Litigation Within a Bankruptcy Case

Adversary Proceedings

An adversary proceeding is the bankruptcy equivalent of a federal civil lawsuit filed inside an existing bankruptcy case. Adversary proceedings are governed by Part VII of the Federal Rules of Bankruptcy Procedure, which incorporates most of the Federal Rules of Civil Procedure with modifications to fit the bankruptcy forum. These deep-dive guides cover five of the most common adversary types encountered in practice.

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About Part VII adversary proceedings

Bankruptcy Rule 7001 lists ten categories of disputes that must be brought as separate adversary proceedings rather than as motions in the main bankruptcy case. The list includes proceedings to recover money or property, to determine the validity, priority, or extent of a lien, to obtain approval for sales free and clear under section 363(h), to object to or revoke a discharge, to obtain an injunction, to determine the dischargeability of a particular debt, to determine the validity of a creditor's claim by a debtor, and to obtain a declaratory judgment on any of the foregoing.

An adversary proceeding is initiated by filing a complaint, served under Rule 7004, and proceeds through pleading, discovery, summary judgment, and trial in much the same manner as ordinary federal civil litigation. Part VII rules adopt Civil Rules 7 through 71 with modifications, supply specialized service rules, and shorten certain deadlines to align with the bankruptcy case schedule.

Each guide below treats one frequently-litigated adversary type. They survey the elements, defenses, common procedural traps, statute-of-limitations issues, and the interplay between the adversary record and the main bankruptcy case.

Adversary deep-dives

Procedural note: Many disputes that practitioners treat as motions actually require adversary proceedings under Rule 7001. Filing the wrong vehicle wastes time and can prejudice substantive rights.