Lamie v. United States Trustee
Citation and Court
540 U.S. 526 (2004), Supreme Court of the United States
Facts
Lamie was an attorney representing a Chapter 7 bankruptcy debtor. After Congress amended 11 U.S.C. § 330(a)(1) in 1994, the provision read awkwardly and appeared to no longer authorize compensation of debtors’ attorneys from the bankruptcy estate. Lamie sought compensation from the estate; the United States Trustee objected. Lamie argued the statute should be read to continue authorizing debtor’s attorney fees because the amendment’s result was unintended and absurd.
Issue
Whether 11 U.S.C. § 330(a)(1), as amended, authorizes payment of a debtor’s attorney’s fees from the bankruptcy estate in a Chapter 7 case.
Holding
The Supreme Court held unanimously that the statute, as amended, does not authorize such fees. Even though the text is awkward and may have resulted from a drafting error, a court cannot rewrite an unambiguous statute simply because its outcome seems unintended or harsh.
Rule / Doctrine
Courts must apply the plain meaning of statutory text, even when the result is awkward, unexpected, or arguably contrary to congressional intent. The Court will not reform a statute under the guise of interpretation to correct what appears to be a drafting error. If the language is clear, the inquiry ends — Congress, not the courts, must correct drafting mistakes.
Significance
Lamie is a leading textualist case illustrating the limits of judicial correction of statutory drafting errors. It demonstrates the Supreme Court’s commitment to applying unambiguous text literally, even where doing so seems to produce a result Congress did not intend, and stands for the principle that oddness or hardship does not justify rewriting a statute.