Antonio Jubis Zacarias, et al. v. Ralph S. Janvey, et al.
Arbitration ERISA DueProcess Securities Privacy JusticiabilityDoctri ClassAction
Whether a district court in a receivership action has Article III jurisdiction to bar investor claims for individual injuries when the receiver lacks standing to bring those claims himself due to the lack of an injury to the receivership estate
QUESTION PRESENTED The Fifth Circuit holds that a receiver who lacks standing to bring investor claims can nonetheless settle those claims, with all settlement proceeds going to the receivership estate, and the district court has jurisdiction to enter bar orders extinguishing the investors’ claims as a condition of settlement. The decision represents an unprecedented expansion of Article II] jurisdiction, contrary to ordinary Article III standing requirements, and directly conflicts with the law of the First, Sixth, Seventh, and D.C. Circuits. The question presented is: Whether a district court in a receivership action has Article III jurisdiction to bar investor claims for individual injuries when the receiver lacks standing to bring those claims himself due to the lack of an injury to the receivership estate.