Background
David Michael Snyder, proceeding pro se, filed a petition seeking permission to appeal several orders issued by the United States Bankruptcy Court for the Middle District of Florida directly to the Eleventh Circuit.
The court’s reasoning
The court explained that it may directly review a bankruptcy court order only if the order meets specific statutory requirements under Section twenty-eight U.S.C. Section one hundred fifty-eight subsection d two. The bankruptcy court declined to certify the orders, and neither a bankruptcy appellate panel, the parties, nor the district court provided certification. Consequently, the court found it lacked jurisdiction to hear the petition.
What it means going forward
The decision reinforces the strict certification requirement for direct appeals from bankruptcy courts, preventing parties from bypassing intermediate review unless specific statutory conditions are met.
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