Article on Bankruptcy Reform and Original Understanding of the Bankruptcy Clause:

Very informative and balanced article by Julie Reynolds in the latest issue of the DC Bar Magazine here. She interviewed me for the article.

My only quibble with this excellent piece is that there is a common mistake at the outset, which is that the Bankruptcy power in Article I, sec. 8 of the Constitution was not actually put into the Constitution just to help debtors. This is usually quite surprising to most people. It was actually put there in large part to help creditors as well--like the Contracts clause, Fair Faith and Credit, and prohibition on state issuance of paper money, Congress's power to "enact uniform laws on the subject of bankruptcies" was designed to enable creditors to collect interstate debts more easily and to eliminate the power of state legislatures to try to discharge the debts of their residents (as often was the case during the Articles of Confederation era). In particular, states used their laws to pass pro-farmer laws that interfered with the ability of banks to collect on farm loans and vesting the Bankruptcy power in the federal government was an effort to restrict the excesses of state legislatures under the Articles.

So, while to modern sensibilities we have come to think of bankruptcy as being primarily about the benefit of the discharge to debtors, under the original understanding of the Bankruptcy clause, it was to a large extent a pro-creditor provision as well. To the extent that it benefited debtors as well, it was primarily intended for commercial debtors such as New England merchants, not what we would today call consumer debtors. In fact, some states retained debtors' prisons for consumer debt well into the 19th century.

The argument is actually more complicated that that and turns to some extent on an interesting linguistic debate over the meaning of the term "bankruptcy," which may have had a very specific meaning at the time, applying only to business, not personal insolvency. For centuries, under English common law, only merchants and traders could be declared "bankrupt," which enabled them to have their debts discharged upon the satisfaction of certain requirements. By contrast, non-merchants had to seek refuge under "insolvency" laws, which did little more than to release a debtor from debtor's prison but did not discharge the debtor from his indebtedness. Thus, many understood the Constitution's grant of power to Congress to regulate "bankruptcies" as creating federal power to regulate only with respect to merchants and traders and not with respect to those individuals traditionally subject to "insolvency" laws, which remained under State control. Others argued that this traditional distinction between had disappeared by the mid-Eighteenth century, such that by the time of the Constitution, the terms became interchangeable so as to give Congress the power to regulate all insolvent debtors.

So for originalists, the open question is whether the traditional distinction was still valid at the time of the Constitution. For the Supreme Court, by contrast, the issue was resolved in 1819 when it ruled that the term "bankruptcy" was not a term of limitation, thus Congress could regulate in both realms (although Congress chose to do so only sporadically during the 19th century, leaving debtor-creditor relations mainly to the states).

I actually have a short essay coming out on the original understanding of the Bankruptcy Clause (as well as the Coinage Clause) but the volume in which it is to be published has been long delayed. Here's an excerpt from that essay on the original understanding of the Bankruptcy Clause:

The Bankruptcy Clause of the Constitution was one Congress's several delegated powers in Article I, Section 8 that were designed to encourage the development of a commercial republic and to temper the excesses of pro-debtor State legislation that proliferated under the Articles of Confederation. Under the Articles of Confederation, the States alone governed debtor-creditor relations, and that led to diverse and contradictory State laws. It was unclear, for instance, whether a State law that purported to discharge a debtor of a debt prohibited the creditor from trying to collect the debt in another State. Pro-debtor state laws also interfered with the reliability of contracts, and creditors confronted still further obstructions in trying to use State courts to collect their judgments, especially when debtors absconded to other states to avoid collection.

A coherent and consistent bankruptcy regime for merchants was also required for the United States to flourish as a commercial republic. The Bankruptcy Clause helped to further the goals of uniformity and predictability within the federalist system. As James Madison observed in Federalist Number 42, "The power of establishing uniform laws of bankruptcy is so intimately connected with the regulation of commerce, and will prevent so many frauds where the parties or their property may lie or be removed into different States that the expediency of it [i.e., Congress's power to regulate bankruptcy] seems not likely to be drawn into question." As Madison suggests, there was little debate over and little opposition to the bankruptcy clause at the Philadelphia convention. Although State law continued to govern most routine debtor-creditor relations, Congress had the authority to override State laws dealing with insolvency.


To clarify the federal-state balance perhaps contemplated by the originalist theory described (which, as noted, remains open to contention)--under this theory Congress could enact "bankruptcy" laws (dealing with discharge of debt) and the states would remain in charge of enacting "insolvent" laws (which historically dealt with release of debtors from debtor's prisons). In Sturges v. Crowninshield (1819) Justice Marshall basically punted the originalist question and held that even if the dividing line between the two was contemplated in Art. I sec. 8, it would be too difficult for the Supreme Court to enforce the line judicially.

Related Posts (on one page):

  1. More on Original Understanding of the Bankruptcy Clause:
  2. Article on Bankruptcy Reform and Original Understanding of the Bankruptcy Clause:
Left-leaning Larry:
Good heavens, Zywicki, you Federalist members are all the same--oppress the poor folks on the back of this "originalist" mumbo jumbo. Surely the Founders were not so cruel as to make people pay their debts. And also, the Founders could not have imagined credit-cards. Therefore, our living Constitution suggests that credit-card debt shoudl be dischargeable 100% of the time; scrap all that luxury load-up stuff of the Reform legislation.
7.25.2005 3:08pm
So for originalists, the open question is whether the traditional distinction was still valid at the time of the Constitution. For the Supreme Court, by contrast, the issue was resolved in 1819 when it ruled that the term "bankruptcy" was not a term of limitation, thus Congress could regulate in both realms

Tell me you aren't really contending that the Supreme Court in 1819 was an activist court that was disregarding original intent?
7.25.2005 4:05pm
Timothy (mail) (www):
Surely the Founders were not so cruel as to make people pay their debts

It's cruel to make people be responsible for that which they have wrought? What possible incentive do people then have to honor the contracts into which they've voluntarily entered?
7.25.2005 5:48pm
Mary Katherine Day-Petrano (mail):
Wow! Maybe original intent can bust out student loans in BK. Especially when it isn't as much a matter of a person taking on the debt as being fraudulently induced to take it on -- for example, where schools reasonably accommodate the disabled and promise great law careers knowing the State and Federal Courts refuse to reasonably accommodate the disabled to enable them to practice their professions there. It does not appear students are merchants or commercial debtors. This would leave the Federal disability anti-discrimination laws to regulate the State insolvency laws. An interesting proposition.
7.25.2005 6:16pm
Daniel Chapman (mail):
He was joking, timothy
7.25.2005 6:38pm
Zywicki (mail):
The case was Sturges v. Crowninshield and it was not an originalist opinion. The Court held that while there was a distinction between insolvent laws and bankruptcy laws it was too difficult to police judicially and so Congress could judge the dividing line. That's why it was not read as a "term of limitation."
7.25.2005 8:00pm
Samuel Gross (mail):
The argument that English common law limited the constitutional scope through originalism of the bankruptcy clause to regulating merchants would create an interesting void of power. States would be unable to discharge an individual's debts under the Contracts clause and the Federal Government would be unable to legislate for individuals to discharge their debts as well because they would be limited to merchants. If there was meant to be a specific prohibition on individual discharge of debts that's a rather odd way of achieving it. The illogical result suggests a broader interpretation of the bankruptcy clause would be appropriate.
7.25.2005 8:26pm

But if a Supreme Court decision 20 years after the signing of the Constitution is not an "originalist" opinion, does that not call into question the merits of today's originalist interpretations? Given the proximity in time, should not that decision be part of the material considered by today's originalists? I realize I'm over my head here in debating originalism with you, but if the Supreme Court, only 20 years after signing, did not subscribe to an originalist view, why should we today?
7.25.2005 9:06pm
Robert Schwartz (mail):
So I guess Corporate Reoganizations are out of the question also.
7.26.2005 12:07am
Bat One (mail):
Given what you say here about the various bankruptcy and insolvency laws, under both the Constitution and the prior Article of Confederation, I wonder how much this very same "mumbo-jumbo" influenced and encouraged the westward expansion during the late 18th century and early 19th century from the coastal regions of the original 13 colonies, across the mountains to the Ohio River Valley, the Mississippi, and beyond.
7.26.2005 4:03am
Paul Gowder (mail):
What does the original meaning of the constitution have to do with it, beyond the simple question of whether it permits personal bankruptcy laws?

Once it does do so, the power has been delegated to Congress, and we have a perfect right in the political sphere to suggest that Congress should use that power in accordance with our CURRENT values, even under an originalist framework. You know, Congress, the legislature? Those people who are supposed to respond to the needs of the public?

None of us on the left have suggested that the bankruptcy "reform" act is unconstitutional, for pete's sakes (although I vaguely recall an interesting argument about some fee increase being kicked around briefly).

Congress has the power to help debtors, under the plain meaning both originally and now of that clause, and so we're right to ask Congress why it declines to do so.
7.26.2005 11:10am
Paul Gowder (mail):
Also, Ms. Reynolds's article is a bit misguided in places (although overall good). For example, she describes the "credit counseling requirement" as an "eat-your-peas rule[] in the debtors' best interests" yet utterly fails to note that the epidemic of fraudulent credit counseling agencies is out of control. Also, WHAT "new consumer protections?" A study or two?!

The idea that a debtor could casually "spend extravagantly and then file for liquidation bankruptcy when the debt becomes overwhelming" is absurd. We do have, you know, bankruptcy judges. Who tend to keep an eye on this sort of thing.

While we're citing bar journal articles, by the way, I offer my own thoughts on the Bankruptcy "Reform" Act in the Oregon Bar Journal. Unfortunately, I only had 800 words, so no option to get into the kind of detail that Reynolds does, but take it for what it's worth, even if that's nothing.
7.26.2005 11:24am
Left-leaning Larry:
Paul Gowder: I believe you are correct. Congress could set up Ch. 7 with no asset exemptions if they want, they way I see it. Or do about anything else for that matter (subject I suppose to 5th Amendment challenges, or would it be the 14th for voiding state exemptions? --Zywicki, help please.)
Timothy: I was most certainly kidding. About everything.
Mary Katherine: Who is the bigger kidder, you or me?
7.26.2005 11:26am
Left-leaning Larry:
Paul Gowder: I read your article.

The means test is also unnecessary. . .This provision thus amounts to an attack on judicial independence as well as punishment for the urban employed.

Question 1:
I assume you mean that cost of living is higher in cities, wages are also higher, thus the std. of living is the same, but the urban lower-middle class will get kicked into Ch. 7?

Other thoughts:
1) Everybody agrees that CC co's have unclean hands in the messy state of consumer affairs in this country.
2) Empirical evidence cannot predict if the "bankruptcy prevention discount" that the Act gives to CC co's will be transferred to consumers.
3) Judges VERY rarely used their discretion to kick a Db into Ch. 13, in my opinion.

Question 2:
means test is uneccessary. . .?
Could you elaborate a little?
7.26.2005 11:38am
Left-leaning Larry:
Correction: Question 1: Obviously--kicked into a repayment plan under Ch. 13
7.26.2005 11:46am
Paul Gowder (mail):

Question 1: Correct. Since the median income is tested statewide, and incomes are higher in cities than they are in rural areas for the same standard of living, the means test creates a disparate impact on urban lower-middle class people with wages that might be above a statewide median. For example, the median income for a family of two in New York State is about 47k. In New York CITY, a family of two living on that amount of money is going to have a very different economic experience (like living with several roommates) than a family of two in Albany with the same income.

Question 2: Section 707(b) of the bankruptcy code permitted the bankruptcy court to "dismiss a case filed by an individual debtor under this chapter whose debts are primarily consumer debts if it finds that the granting of relief would be a substantial abuse of the provisions of this chapter."

The mere fact that judges don't often exercise this power doesn't mean judges are to lenient. The more likely reason seems to me to be that there simply isn't that much abuse!
7.26.2005 12:01pm
Left-leaning Larry:
Well, there either isn't much abuse, or the dockets are too jammed for Bankr. judges to dig deep and have further evidentiary hearings on substantial abuse questions.
7.26.2005 12:04pm
Paul Gowder (mail):
Maybe I've always been lucky enough to practice in courts with lenient dockets (and I've only been involved in a couple of bankruptcy cases), but I've never seen a judge, when a party (i.e. the US trustee) brings a motion, decline to hold a necessary evidentiary hearing on the ground that the docket is too full...
7.26.2005 12:16pm
Left-leaning Larry:
The Act will be an interesting experiment. I am a cautious optimist about it. 2 years from now I think we will have a better feel for the repercussions that will result from this law.

Even the best empirical law review articles only sample one Bankr. district for a limited period (Don't have the cite but I have seen one from IL, and one from an IN district). Plus trends, can change frequently with new personnel on the courts, or new devices employed by the financial services industry.

Largely, matters such as whether Bankr. courts were vigilant to 707 questions are a matter of impression for practitioners.
7.26.2005 12:28pm
Paul Gowder (mail):
As you can tell from my op-ed, I'm a severe pessimist about it... why couldn't they have just cracked down on the credit card companies? Lets face it, the credit card companies prey on the financially clueless. The fact that they give out credit cards like halloween candy to college freshmen is only the most obvious of the abuses. They know that even if a few go banko, the vast majority will struggle to deal with credit card debt for years into the most productive time of their lives.

Morally, credit card companies who pitch to clueless college students are, to my mind, at about the same level as heroin dealers. Why should we be subsidizing them? (And then there's the payday lenders, the predatory home lenders, etc.)

Here's what we really need to "reform" the problem of consumer debt:

1. Federal usury laws. (OR at least an act of Congress de-preempting state usury laws for national banks -- how come all the federalist republicans aren't up in arms about that? States can't even regulate credit card lending practices in their jurisdictions!)

2. Legislatively imposed minimum lending standards, like "no unsecured debt over $500 to people with zero income or assets" and "no marketing of credit cards to college students."

3. Single payer health care.

4. Carthage must be destroyed.
7.26.2005 12:55pm
Samuel Gross (mail):
While the update does clarify the theory slightly; it still does not address the underlying fact that even if the states could prevent people from being put into debtor's prison they would be unable, under the contract clause, from expunging the debt and providing the relief their citizens want because of the Contracts clause. The Federal government would also be unable to expunge that debt. Again, this is an illogical conclusion since in a federalist style of government where one of the sovereigns has plenary power and the only limits on that are specified superior powers (e.g. the constitution and federal law) it doesn't make any sense, absent a specific prohibition, that individual debts could be discharged neither by the federal government nor the states.

Maybe I'm misunderstanding the constitutional law, but still that basic contradiction seems to seriously undermine the argument.
7.26.2005 11:25pm
Stephen J. Behm (mail) (www):
Constitutional history notwithstanding (and I very much disagree with Zywiki's analysis), the bankruptcy act is entirely cynical and shameful. The so-called $400.00 "bankruptcy tax" trumpeted by one of the lobbyists is particularly misleading because it is realy predicated on the 5 billion or so that the credit card industry will save over the next several years than on any definitive factual analysis or formal study. I find it stunning that Zywiki was virtually the only academic that supported this thing. The onus of abuse and fraud is on the credit industry and it is not coincidental that the number of bankruptcies soared when credit card solictiations soared. This supporters of this law and the enactment of it remind me of the influence peddling of the landed gentry in 18th century Europe. Evidently, these days, only those companies and individuals with money can peddle forth the sponsorship and enactment self-serving legislation. Regardless of one's take constitutionally, I am sure the founders did not and could not conceive of a marauding credit industry fleecing the public with 30% interest rates, transaction fees, etc. A good national usury law and intense regulation would do much to curb its purloining of the general public. I wonder if Captial One would continue airing its commercials with those plundering barbarians if it truly appreciated the irony.
7.27.2005 12:28am
Robyn Whitman (mail):
To Mr. Gowder and LLL:

Due to judicial mandate in the MDNC a few years ago, the USBA files 707(b) motions and the courts schedule discovery deadlines and evidentiary hearings. We have not used a "means test" but review petitions for several red flags, including apparent or suspected disposable income ("suspected" due to, e.g., 401k contrib on budget, huge payment for residence [or beach condo] they intend to retain and which makes budget unreasonable - especially in light of request for discharge of six-figure credit card debt - , tuition for private schools or children's college, etc.). These motions are a big pain for debtors, their attorneys, and the BA's office, but I expect that the current system is much more fair (and effective) than the new law will be. We currently have appx. 25 707(b) matters pending, with five scheduled for hearing in 8/2005. 707(b) motions are also filed in the EDNC, but with less frequency and usually on the larger-income cases.
7.27.2005 12:43pm
Paul Gowder (mail):
Ms. Whitman: thank you. That is consistent with a lot of my intuitions about how the bankruptcy courts currently operate, which is not, contrary to the suggestions of the sponsors of "reform," casually permitting those who can afford to pay their debts to abuse the bankruptcy system.
7.27.2005 1:17pm
Bruce H. Mann (mail):
You repeat many of the standard misconceptions about the purpose of the bankruptcy clause of Art. I, sec. 8 of the Constitution and about what bankruptcy meant to members of the founding generation, but you are mistaken in your history. Contrary to your assertion, the bankruptcy clause was not "designed to enable creditors to collect interstate debts more easily." There are other historical errors in your post, but I will start with one. I note others in a longer post at

Many people in the 1780s and 1790s argued for the importance of a bankruptcy system to a commercial society. But pamphlets, letters, and Congressional debates leave no doubt that commercial actors valued bankruptcy process for the discharge that enabled them to start over with a clean slate. Widespread business collapses after the Revolution deepened the understanding of failure as the downside of entrepreneurial risk. This made failure the potential common fate of all merchants, all of whom were simultaneously debtors as well as creditors. For merchants, bankruptcy process was an attempt to control the consequences of failure by providing for an orderly distribution of the debtor's assets and by rewarding the debtor with a discharge that would enable him to venture into the market again. Bankruptcy process benefitted creditors and debtors alike. That both creditors and debtors understood this is further reflected in the large number of collusive, or cooperative, filings under state and later federal acts that were nominally involuntary.

These corrections rest on substantial archival evidence, which I explore more fully in Republic of Debtors: Bankruptcy in the Age of American Independence (Harvard University Press, 2002). Historical accuracy matters, and never more so than when it is invoked in modern policy debates.
7.28.2005 11:13am
Zywicki (mail):
I don't see where what you said differs from what I said. The article is about consumer bankruptcy and it states, "The Founding Fathers believed that bankruptcy relief was every citizen's right" and then implies that this is the reason it was included in the Constitution. I note in my post that the purpose of the law was both pro-creditor and pro-debtor. But as both you and I note, to the extent it was a pro-debtor provision, it was for merchants, not consumer debtors.

As for the pro-creditor purpose of the bankruptcy clause, isn't it true that one of its purposes was to deal with the problem of state legislatures attempting to enact pro-debtor laws and that one purpose of this grant to the federal government in Art. I sec. 8 was to vest in the federal government the sole power to enact laws governing discharge of debts?

So unless you are saying that the bankruptcy clause of the federal constitution was designed to guarantee a fresh start for consumers then I don't see what you are correcting. If you are saying that, and agreeing with the DC Bar article, then this is surely an argument that is not commonly accepted.

Also, I did not invoke this argument as part of a modern policy debate. I invoked it as a historical point regarding the DC Bar article.
7.29.2005 1:34pm
Bruce H. Mann (mail):
As Todd acknowledges in the longer version of his post at, he does not read me as agreeing with the D.C. Bar Magazine article that the founders "believed that bankruptcy relief was every citizen's right." Here we agree. However, when he says in his longer post that "we seem to be saying the same thing in all substantive ways," he is wrong. We disagree profoundly, and the disagreement is a matter of historical accuracy.

In the first paragraph of his original post, Todd claims that the bankruptcy clause was put in the Constitution "in large part to help creditors" and that the federal bankruptcy power " was designed to enable creditors to collect interstate debts more easily." Neither of these statements is correct, as I thought I had explained in my original post. Todd now says that in his original post he notes that "the purpose of the law was both pro-creditor and pro-debtor," (I assume he means the purpose of the bankruptcy clause, which is what he first said and what I responded to, rather than bankruptcy law), but since he gives no example in either post of how the bankruptcy power would benefit debtors, I assume that he means what he first said, that the bankruptcy clause was primarily pro-creditor in purpose.

The bankruptcy power did have pro-creditor aspects, but that does not change the fact that it had nothing to do with facilitating the interstate collection of debts and that it was not designed "to temper the excesses of pro-debtor State legislation," as Todd claims. The pro-debtor state legislation creditors complained of (although not uniformly) were tender laws and stay laws, neither of which were addressed by bankruptcy. And the "pro-farmer laws that interfered with the ability of banks to collect on farm loans" that Todd mentions in his original post did not, as best as I can tell, exist at the time of the Constitutional Convention. There were three banks in the United States in 1787, and none made farm loans.

As I stated in my original post, the underlying issue with regard to bankruptcy at the Constitutional Convention was whether a legislative discharge obtained by a debtor in one state would protect him from arrest when he traveled to another state. Contrary to Todd's assertion in his longer post, this is not simply a different way of expressing what he said, that the bankruptcy power "was designed to enable creditors to collect interstate debts more easily." It has nothing to do with collecting interstate debts and everything to do with guaranteeing the reach of the debtor's discharge. This is entirely consistent with all of the contemporary arguments for bankruptcy, which justified its importance on the basis of the fresh start of a discharge that would enable debtors to return to being productive members of society and supporting their families. The benefit to creditors lay in the belief that the availability of a discharge would prevent debtors from wasting their assets in futile efforts to regain solvency and therefore preserve more for creditors.

This, of course, raises the question of which debtors? As I discussed at length in Republic of Debtors, the argument that only merchants and traders unavoidably incurred economic risk and that everyone else merely grew poorer gained popularity before the Revolution. And in the Congressional debates on proposed bankruptcy bills in the 1790s, the argument that a bankruptcy law was important to a commercial republic rested on an identification of bankruptcy with commercial debtors. But this is not the same thing as saying, as some originalists evidently do, that bankruptcy referred only to commercial debtors. As I stated in my initial post, the fact that colony and state bankruptcy laws did not routinely include occupational restrictions belies this. Even when they did include occupational restrictions, the division between bankruptcy and insolvency proceedings was not that business debtors qualified for bankruptcy and consumer debtors for insolvency. Rather, it was typically that business debtors whose occupations and levels of indebtedness met the statutory requirements qualified for bankruptcy, while all other business debtors and all non-business debtors qualified only for insolvency process. So the characterization of insolvency process as a "consumer" process is inaccurate. And the debtors' prisons that some states maintained into the nineteenth century held both business and non-business debtors, regardless of whether bankruptcy was available.

In his longer post, Todd invokes Marshall's opinion in Sturges v. Crowninshield to note that contemporaries distinguished clearly between bankruptcy laws and insolvency laws. Of course they did. The point I made, and Todd quotes, was that "the distinction between business and personal insolvency was hardly a clear one." This was simply a statement of the difficulty of distinguishing clearly between business and personal financial distress, not of trying to distinguishing between bankruptcy process and insolvency process.

In sum, Todd is mistaken in his history. He opened his original post by stating that the bankruptcy power "was actually put there [Art. I, sec. 8] in large part to help creditors." Actually, it was put there in large part to help debtors, and to state otherwise is historically inaccurate.
7.30.2005 4:58pm
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10.11.2005 8:58pm
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7.20.2006 1:43am