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AResearch Serve
Siegel v. Fitzgerald: Supreme Court Makes
Rare Comment on the Bankruptcy Clause's
Uniformity Requirement
July 1, 2022
On June 6, 2022, the Supreme Court decided Siegel v. Fitzgerald, holding that the Bankruptcy Judgeship
Act of 2017 (the 2017 Act) violated the uniformity requirement of the U.S. Constitution's Bankruptcy
Clause. The 2017 Act increased quarterly administrative fees in most, but not all, federal districts,
resulting in different fees on debtors depending on the district in which they filed for bankruptcy. In its
fourth opinion ever on the uniformity requirement, the Supreme Court unanimously ruled that the 2017
Act established an arbitrary geographic disparity that contravened the Bankruptcy Clause. In so ruling, the
Court touched on the limits that Congress faces when enacting legislation to address geographic
problems. This Sidebar provides an overview of the uniformity requirement and analyzes the Siegel
decision. It concludes with post-Siegel considerations for Congress.
The Uniformity Requirement
The Bankruptcy Clause bestows upon Congress the power to establish uniform Laws on the subject of
Bankruptcies throughout the United States. A bankruptcy statute thus must apply uniformly to a defined
class of debtors to pass constitutional muster.
In three prior opinions, the Court has interpreted the uniformity requirement as flexible, but only to a
point. First, in Moyses v. Hanover National Bank, the Court rejected a challenge to the constitutionality of
the Bankruptcy Act of 1898, a statute that permitted individual debtor exemptions under state laws. The
Court held that the uniformity requirement did not require Congress to eliminate existing state
exemptions in bankruptcy laws, and that the general operation of the law is uniform although it may
result in certain particulars differently in different States.
Second, in the Regional Rail Reorganization Act Cases, the Court assessed the Regional Rail
Reorganization Act of 1973, which applied only to rail carriers operating within a defined region of the
country. Although the Act differentiated between regions on its face, there were no railroad
reorganizations pending outside of that region, allowing the Court to conclude that in practice the statute
operate [d] uniformly upon all bankrupt railroads in existence. In upholding the statute, the Court also
Congressional Research Service
https://crsreports.congress.gov
LSB10782
CRS Legal Sidebar
Prepared for Members and
Committees of Congress](ViewImageLocal?handle=hein.crs/govehyb0001&div=1&collection=&method=preview&ext=.png&size=3)
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