Fed. R. Bankr. P. 3007 11 U.S.C. Section 502

Claims Objection Procedure

Rule 3007, the bases for objection (allowance, priority, classification), the evidentiary standard, and contested-matter mechanics.

The proof-of-claim foundation

A claim against a bankruptcy estate is asserted by filing a proof of claim on Official Form 410, as authorized by 11 U.S.C. Section 501 and governed by Federal Rule of Bankruptcy Procedure 3001. The proof of claim must identify the basis for the claim, the date the debt was incurred, the account number or other identifier, the amount, the security (if any), and the priority (if any). Rule 3001(c) requires that the proof of claim attach the writing on which the claim is founded, or - if the writing is unavailable - a statement explaining the circumstances. Rule 3001(c)(2) imposes additional itemization requirements for open-end and revolving consumer credit claims.

A properly filed proof of claim that satisfies the substantive and procedural requirements of Rule 3001 constitutes prima facie evidence of the validity and amount of the claim. Rule 3001(f). This presumption is the cornerstone of the burden-shifting framework that governs claims objections.

Section 502 - the allowance framework

11 U.S.C. Section 502(a) provides that a claim filed under Section 501 is deemed allowed unless a party-in-interest objects. Section 502(b) enumerates the substantive grounds on which a claim may be disallowed:

Beyond Section 502(b), claims may also be subject to subordination under Section 510, recharacterization (e.g., treating a purported loan as an equity contribution), or partial disallowance for unreasonable charges. Section 502(d) provides for disallowance of any claim of an entity from which property is recoverable under specified avoidance provisions until the entity has paid the avoidable transfer back to the estate.

Rule 3007 - filing and serving the objection

Federal Rule of Bankruptcy Procedure 3007 governs the form and service of a claim objection. The 2017 amendments to Rule 3007 substantially restructured the rule. The objection must be filed with the court and served on the claimant, the debtor, and the trustee. Service on the claimant is made at the address on the proof of claim, with required additional service on any address designated for service of process and on any attorney listed on the claim. The objection must be served at least 30 days before the hearing date (Rule 3007(a)(1)).

An objection must state the grounds for the objection with particularity. A bare denial that the claim is owed is generally insufficient; the objection should identify the specific Section 502(b) ground (or other ground), describe the factual or legal basis, and (if amount-only) state the amount the objector contends should be allowed.

Rule 3007(d) permits omnibus objections grouping multiple claims under specified circumstances: where the claims are filed by the same entity, where the same legal or factual basis applies, or for certain specified categories such as superseded claims or claims that have been satisfied. Omnibus objections are subject to strict limitations to protect individual claimants' procedural rights.

The burden-shifting framework

The interaction of Rule 3001(f) and Section 502(a) produces a settled burden-shifting framework:

  1. The claimant files a proof of claim that satisfies Rule 3001's substantive and procedural requirements. The claim is prima facie valid.
  2. The objecting party comes forward with evidence sufficient to rebut the prima facie validity. The evidence must be sufficient to demonstrate a true dispute - mere assertion of objection is insufficient.
  3. If the objector rebuts the prima facie case, the burden of going forward shifts back to the claimant to prove the claim by a preponderance of the evidence.
  4. The ultimate burden of persuasion remains with the claimant throughout.

The framework is summarized in In re Allegheny International, Inc., 954 F.2d 167 (3d Cir. 1992), and has been adopted by every circuit. A proof of claim that fails to satisfy Rule 3001's requirements - typically by failing to attach the underlying writing - does not lose the right to be allowed, but it loses the prima facie presumption; the claimant must then prove the claim from the start.

Contested-matter mechanics under Rule 9014

A claim objection is a contested matter under Rule 9014 unless it joins a request for relief listed in Rule 7001 (in which case an adversary proceeding is required). Rule 9014 incorporates many adversary-proceeding rules into contested matters by reference, including most discovery rules. The court may direct that additional adversary-proceeding rules apply.

The contested-matter procedural skeleton:

If the objection raises a complex factual dispute or seeks affirmative relief (such as a determination of the validity, priority, or extent of a lien under Rule 7001(2), or an injunction under Rule 7001(7)), the objection must be re-filed or supplemented as an adversary complaint.

Claim transfer and standing

A claim may be transferred under Rule 3001(e). The transferee files a notice of transfer with the court, which serves notice on the transferor. After the unobjected window expires, the transferee is substituted as the holder of the claim. The debtor's standing to object to a claim is well-settled in cases in which the debtor has a pecuniary interest in the allowance of the claim (e.g., a solvent estate, a Chapter 11 case in which the debtor remains in possession, or a Chapter 13 case where the plan funds claim allowances).

Common objection theories

The most frequently asserted objection theories in consumer cases include:

Insufficient documentation under Rule 3001(c)

The proof of claim lacks the writing on which the claim is based, or - in an open-end consumer credit claim - lacks the statement of account history, contract attachment, or other Rule 3001(c)(3) information. The objection rebuts the prima facie presumption and forces the claimant to come forward with documentary proof. Many objections of this type are resolved by amendment of the proof of claim.

Statute of limitations

The claim is barred under state law because the limitations period had run before the petition date. Section 502(b)(1) makes a claim disallowable to the extent it is unenforceable under applicable law, which includes time-bar defenses available to the debtor outside bankruptcy.

Improperly claimed priority

The claimant has asserted priority status under Section 507 to which it is not entitled - for example, classifying a general unsecured claim as a Section 507(a)(8) tax priority, or treating a non-domestic-support obligation as a Section 507(a)(1) priority. The objection challenges classification rather than allowance; the claim may still be allowed at general unsecured status.

Improperly claimed secured status

The claimant has asserted secured status under Section 506 to which it is not entitled - for example, claiming a lien that was never recorded, was released, or is subordinate to a senior lien that consumes the available collateral value. A motion to determine the secured status of the claim under Rule 3012 may be combined with the claim objection.

Claim previously satisfied

The claim was paid before the petition date or has been satisfied by foreclosure on the collateral or by setoff. The objection identifies the satisfaction and produces supporting evidence.

Claim allowance and Section 1325 (Chapter 13)

In Chapter 13, claim allowance is the foundation of plan distributions. A confirmed Chapter 13 plan binds creditors regardless of the amounts ultimately allowed; the plan typically estimates allowed amounts and provides for adjustment as claims are allowed or disallowed. The claim-objection process runs in parallel with plan distributions, with disbursements being held in escrow or adjusted as objections are resolved.

The proof of claim's prima facie validity is the default; the objector must come forward with rebuttal evidence. A claim objection that does not present evidence sufficient to rebut the prima facie validity is subject to denial without further proceedings. Conversely, a proof of claim that fails to comply with Rule 3001's documentation requirements loses the prima facie presumption and must be proven on the merits.

Related statutes and authority

Open Bankruptcy Project cross-references

This page provides general information about claims objection procedure. It does not constitute legal advice.

Last modified: 2026-05-22