Barton v. Barbour
In Barton v. Barbour, 104 U.S. 126, 127, 26 L.Ed. 672 (1881), the Supreme Court ruled that the common law barred suits against receivers in courts other than the court charged with the administration of the estate.
The Supreme Court ruled that before suit is brought against a receiver, leave of the court by which the trustee was appointed must be obtained.
The Court stated:
So, in cases of bankruptcy, many incidental questions arise in the course of administering the bankrupt estate, which would ordinarily be pure cases at law, and in respect of their facts triable by jury, but, as belonging to the bankruptcy proceedings, they become cases over which the bankruptcy court, which acts as a court of equity, exercises exclusive control. Id. at 134.