Rexnord Holdings, Inc. v. Bidermann

In Rexnord Holdings, Inc. v. Bidermann, 21 F.3d 522, 527 (2d Cir. 1994) the district court heard arguments of counsel regarding the entry of judgment in favor of plaintiff. At the conclusion of the hearing, which began at 2:30 p.m., the district court stated "I'm going to order that judgment be entered in favor of plaintiff in the amount of $ 12,946,748 principal and accrued interest...So I'm going to endorse the original documents to that effect on this application...I want to enter this today." Id. at 524-525. That same day, defendant's counsel advised the district court and plaintiff by letter that defendant had filed a petition for bankruptcy, pursuant to Chapter 11 of the Bankruptcy Code, at 3:18 p.m. that day, following the hearing. The following day, the money judgment was entered on the district court docket by the court clerk. Id. at 525. The defendant in Rexnord argued, inter alia, that the judgment of the district court should not be given effect because it was docketed after the filing of defendant's Chapter 11 petition, and thus was entered in violation of the automatic stay in bankruptcy. Id. at 527. The Second Circuit rejected that argument, concluding that they "do not believe that the simple and 'ministerial' act of the entry of a judgment by the court clerk constitutes the continuation of a judicial proceeding under section 362(a)(1)." Id. The Second Circuit cited, inter alia, Teachers Ins. v. Annuity Ass'n v. Butler, 58 Bankr. 1019, 1022 (S.D.N.Y.) in which the court held that the filing of a signed judgment and entry on the docket by the clerk was a ministerial act that did not violate the automatic stay provisions of Section 362. Id. at 528. Thus, the Rexnord court held that "the judicial proceedings were concluded at the moment the judge directed entry of judgment, a decision on the merits having then been rendered." Id. at 528.