The Never-ending Story The Statute of Limitations for Concealing Assets from a Bankruptcy Estate

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Nov 2001

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"What is the justification for depriving a man of his rights, a pure evil as
far as it goes, in consequence of the lapse of time?"

 —Oliver W. Holmes Jr., The Path of the Law, <a href="http://www.westlaw.com/find/default.asp?rs=CLWP2.1&vr=1.0&cite=… Harv. L. Rev. 457, 476 (1897)</a>
</blockquote>

Statutes of limitation are part of the law not by virtue of judicial fiat, but as
a consequence of legislative action.<a href="#3" name="3a">3</a> Indeed, the common law fixed no limitation
period for bringing legal action against a person, regardless of whether the claim was
civil or criminal.<a href="#4" name="4a">4</a> Statutes of limitation are the product of a legislative balance
between "repose on the one hand, and vindication of both public and private legal
rights on the other."<a href="#5" name="5a">5</a> As Justice Holmes observed in the quote set forth above,
the very notion of preventing any person from remedy to vindicate his or her rights—or
to prevent a person from seeking redress for a grievance done him or her—seems at best
counter-intuitive, and unjust at worst.

Half a century after Holmes's critique of the concept of limitations, Associate
Justice Robert Jackson offered the classic explanation of the purpose and policy behind
such laws:

<blockquote>
Statutes of limitation find their justification in necessity and convenience rather
than in logic. They represent expedients rather than principles. They are
practical and pragmatic devices to spare the courts from litigation of stale claims
and the citizen from being put to his defense after memories have faded,
witnesses have died or disappeared, and evidence has been lost. They are by
definition arbitrary, and their operation does not discriminate between the just
and unjust claim, or the voidable and the unavoidable delay. They have come
into the law not through the judicial process but through legislation... The
history of pleas of limitation shows them to be good only by legislative grace
and to be subject to a relatively large degree of legislative control.<a href="#6" name="6a">6</a>
</blockquote>

The time periods set by legislative bodies in America restricting the prosecution of
certain crimes varies greatly.<a href="#7" name="7a">7</a> The same holds true of various classes of crimes
prosecuted in the federal criminal justice system in general, and of various bankruptcy
crimes, specifically.

The general statute of limitations for most non-capital offenses, which includes
bankruptcy crimes, is <a href="http://www.westlaw.com/find/default.asp?rs=CLWP2.1&vr=1.0&cite=… U.S.C. §3282</a>. This statute requires indictment
or the filing of an information within five years after the offense has been
committed. The limitations period in §3282 applies to such bankruptcy crimes as
false oath or account, false declarations or statements under penalty of perjury, false
claims, receipt of material amount of property from a debtor, trading on a discharge,
destruction or falsification of records, and withholding recorded information.<a href="#8" name="8a">8</a> Section
3282 also governs other offenses that persons who attempt to defraud the bankruptcy
system may commit in the process, such as mail and wire fraud. In cases where one
or more persons work together to commit a bankruptcy crime, the limitations period runs
five years from the date that the last act in furtherance of the conspiracy was
committed.<a href="#9" name="9a">9</a> Congress has, however, established a different limitations period for the
time in which persons who conceal assets from a bankruptcy estate may be prosecuted.

<h3>Special Limitations Period for Concealment</h3>

The statute of limitations for concealment offenses is controlled by <a href="http://www.westlaw.com/find/default.asp?rs=CLWP2.1&vr=1.0&cite=… U.S.C.
§3284</a>. This provision extends the limitations period for concealment of assets
charged under <a href="http://www.westlaw.com/find/default.asp?rs=CLWP2.1&vr=1.0&cite=… U.S.C. §152(1)</a> and <a href="http://www.westlaw.com/find/default.asp?rs=CLWP2.1&vr=1.0&cite=… U.S.C. §152(7)</a>—and arguably
for any concealment of assets charged under §157, as well. According to the text
of the statute, it is the nature of the crime committed, and not necessarily the
provision under which the defendant is prosecuted, that controls. In full, §3284
reads as follows:

<blockquote>
The concealment of assets of a debtor in a case under title 11 shall be
deemed to be a continuing offense until the debtor shall have been finally
discharged or a discharge denied, and the period of limitations shall not begin
to run until such final discharge or denial of discharge.
</blockquote>

By its text, this limitations period is not tied to any particular statute, but to
the offense of concealment of assets of a debtor. At a minimum, it would seem
certainly to apply to concealment offenses charged under <a href="http://www.westlaw.com/find/default.asp?rs=CLWP2.1&vr=1.0&cite=… U.S.C. §152</a> and
§157.

Theoretically, this limitations period might also be applied to mail and wire fraud
offenses where the mails or interstate wires were used to facilitate a concealment of
a debtor's assets from a bankruptcy estate. At least one federal court has concluded,
however, that the general five-year limitations period applies to false statements made
for the purpose of facilitating the concealment of assets, rather than the continuing
offense statute of limitations applicable to concealment.<a href="#10" name="10a">10</a>

In any event, the statute of limitations for concealing assets from a bankruptcy
estate is five years from the time a debtor has received a discharge or an order is
entered denying a discharge. The time frame in which a debtor might obtain a
discharge—or be denied one—varies from chapter to chapter.

Eligible chapter 7 debtors receive a discharge 60 days following the first date
set for the first meeting of creditors (§341 meeting), absent an objection to
discharge by a creditor, the trustee or the U.S. trustee.<a href="#11" name="11a">11</a> Thus, the limitations
period for concealment will typically begin to run from 60 days after the bankruptcy
was filed in a typical chapter 7 no-asset case. A corporation does not receive a
chapter 7 discharge, and thus the question of what limitations period applies to
corporate debtors that conceal assets is rather murky.<a href="#12" name="12a">12</a> Three possibilities exist:
(1) no limitations period applies; (2) the general five-year limitations period
applies; or (3) the concealment is an ongoing offense that must be prosecuted within
five years of when the last event that could be considered the functional equivalent
of a discharge occurred.

In a chapter 11 reorganization, the discharge is effective when the plan is
confirmed.<a href="#13" name="13a">13</a> Note that a corporate debtor does not get a chapter 11 discharge if
the plan provides for a liquidation of substantially all assets and it does not
continue in business after the plan has been consummated.<a href="#14" name="14a">14</a> Consequently, confirmation
or denial of confirmation are the events that trigger the beginning of the limitations
period for concealment in a common chapter 11 case.

Chapter 12 and 13 debtors receive a discharge after they have completed all
payments called for in their plan during the post-confirmation, pre-discharged
period,<a href="#15" name="15a">15</a> unless they receive a hardship discharge upon application to the bankruptcy
court. Because a chapter 12 or 13 plan may take six months to a year to get
confirmed, and a chapter 12 or 13 plan can extend from three to five years, the
limitation period for concealment in a normal chapter 12 or 13 may not start to
run until five or more years after the case was first filed.

<h3>What Happens When the Discharge Is Not Granted or Denied</h3>

The text of §3284 does not explain, however, what the limitations period is
for concealment cases where a discharge is neither granted nor denied. Such situations
can arise when the case is dismissed on motion by a party, the court or voluntarily
by the debtor. The courts are split over what limitations period to apply in
concealment cases if there is no discharge provided by statute, or if there is no
order entered in the bankruptcy case discharging or denying a discharge to the debtor.
Some early cases hold that the statute of limitations remains open-ended.

<h3>The Early Debate</h3>

In United States v. Newman,<a href="#16" name="16a">16</a> the U.S. District Court for the Southern
District of New York was called on in 1945 to decide whether an indictment
charging the defendant with concealing property from a trustee in bankruptcy should be
dismissed on the grounds that it was barred by the predecessor to §3284 (<a href="http://www.westlaw.com/find/default.asp?rs=CLWP2.1&vr=1.0&cite=…
U.S.C. §52</a>). The government charged the defendant with concealing property from
the trustee on or about Sept. 14, 1937. The applicable statute of limitations
then in force was three years from the date the offense occurred. The indictment was
filed Feb. 8, 1945. In 1938, the statute of limitations for concealment
offenses was amended to read "the offense of concealment of assets of a bankrupt shall
be deemed to be a continuing offense until the bankrupt shall have been finally
discharged, and the period of limitations herein provided shall not begin to run until
such final discharge."

<blockquote><blockquote>
<hr>
<big><center>
[M]ore than half a century after the courts first began
to struggle with deciding what limitations period applies
in concealment prosecutions when the bankruptcy court has
not ruled on the bankrupt's discharge, the same question
remains unanswered by Congress.
</center></big>
<hr>
</blockquote></blockquote>

The court denied that motion to dismiss because the defendant had made no showing
that he received a discharge. The defendant complained that if the statute of
limitations was construed in this manner, "bankrupts will or may suffer injustice and
sound public policy be violated." The Newman court felt compelled to apply the statute
as "its language plainly demand[ed.]" The court further noted that if its interpretation
raised such concerns, the proper remedy was to seek amendment of the statutes in
question. The court also observed that '[u]nwise public policy is not the equivalent
of lack of power," and Congress, not the courts, possessed the authority to
legislate in the area. The motion to dismiss was denied.

A few months after Newman was decided, the U.S. District Court for the
District of Maryland, in United States v. Fraidin,<a href="#17" name="17a">17</a> reached the opposite
conclusion.

In Fraidin, six defendants were indicted on Feb. 27, 1945, for unlawfully
concealing assets from the receivers and the trustee of David Fisher's bankruptcy
estate. Fisher was never granted a discharge nor did he ever apply for one. The
indictment alleged that, beginning in June 1938, the defendants unlawfully,
knowingly, willfully, feloniously and fraudulently concealed a large amount of personal
property belonging to the estate, such as "certain goods, wares, merchandise and
moneys." Two defendants argued that their prosecution violated the applicable statute of
limitations (<a href="http://www.westlaw.com/find/default.asp?rs=CLWP2.1&vr=1.0&cite=… U.S.C. §52d</a>). These defendants asserted, among other claims,
that the offense of concealment occurred, if at all, more than three years before
the filing of the indictment on Feb. 27, 1945, and was, therefore, barred
by the very terms of the statute as it stood before amendment. They further argued
that, because the period in which an indictment could be brought for concealment of
assets against them might run indefinitely because the bankrupt could never obtain a
discharge, the statute was invalid.

The Fraidin court held that the new statute of limitations applied "because
enactments limiting the time for the prosecution of offenses may be changed or repealed
altogether in any case where the original period of limitations has not yet completely
run." It nevertheless concluded that the prosecution was barred under its interpretation
of the statute. The court first explained that prior to the 1926 amendments to
the Bankruptcy Act when the period of limitation for the prosecution of offenses was
made three years, it had been one year. The "Chandler amendments," defining the
crime of concealment as "a continuing offense until the bankrupt shall have been finally
discharged," was the result of conflicts in decisions interpreting the meaning of
"concealment" under the Act. Prior to the Chandler amendments, some courts had held
that the statute of limitations in concealment prosecutions did not begin to run until
the last overt act had been committed. However, the court could not decide when this
overt act occurred. Some courts concluded the period did not begin to run until a
trustee qualified by giving bond, and others held that it did not begin until the
trustee had been elected by creditors or appointed by the court on their failure so
to elect. In attempting to set a bright-line standard, however, Congress made a
gaping error: It incorrectly assumed that there would ultimately be a discharge of
the bankrupt in every bankruptcy case.

The Fraidin court framed the question before it as to whether Congress may "afford
to some offenders the benefit of a definite limitation within which they may be
prosecuted, while at the same time affording no time limitation whatsoever to other
offenders within which they may be prosecuted, because in their cases the specified
event has not happened, and cannot happen." Its analysis, while lengthy, offers
little guidance on what rule of law prohibited the foregoing result. The fact that
the court was discussing two distinct classes of defendants suggests that it was
weighing equal protection considerations decades before the U.S. Supreme Court first
ruled that the Due Process Clause of the Fifth Amendment contained an
equal-protection component.<a href="#18" name="18a">18</a> Other language in the opinion suggests that the court
was basing its decision on the unfair treatment it perceived resulted from the law as
it was written, which was not an uncommon practice during the Lochner era,<a href="#19" name="19a">19</a> when
federal courts had been afforded considerable leeway in deciding policy matters. Ignoring
the text of the statute, the court based its decision on "the intent of Congress"
to "place all persons who may have concealed bankruptcy assets in the same class as
respects limitations, and not to differentiate between those cases in which the bankrupt
might have been discharged and those in which he might not." Rather than striking the
three-year statute of limitations, the court decided to interpret it so that it also
included the denial of discharge as well.

During the same time period, in United States v. Nazzaro,<a href="#20" name="20a">20</a> the U.S.
District Court for the Southern District of New York, acknowledging the "exhaustive
opinion" in Fraidin, observed that that the provisions of the statute were not
ambiguous, and that "Congress and not the courts must determine if and when
prosecution for an offense should be barred by limitation." The Nazzaro court further
observed that no "legislative history has been found or called to the attention of the
court indicating that Congress intended otherwise than it expressly provided." The
Nazzaro court elected to follow the Newman decision rendered by another judge within its
district, rather than Fraidin.

The U.S. District Court for the Middle District of Pennsylvania added its voice
to the debate on how the concealment statute of limitations should be interpreted in
1947. In United States v. Ganaposki, the court was confronted with a case where
an involuntary petition in bankruptcy had been filed against the defendant on June
15, 1938, the defendant was adjudicated a bankrupt, and an indictment was
returned on Oct. 22, 1946. He allegedly concealed property from the estate from
Aug. 15, 1938, until he was charged. The defendant had not, up until the
date of the indictment, received a discharge. The defendant moved to dismiss the
indictment on the grounds that (1) the prosecution was barred by the statute of
limitations, (2) the amendment to the statute of limitations did not apply equally
to all debtors, and (3) on other grounds.

While the defendant relied on Fraidin in support of his argument that the amendment
did not apply to all debtors equally, the Ganaposki court proclaimed that it was
within the power of Congress to make such a classification, that the law applies with
equal force to all within the class, and the defendant "points to nothing by way of
citation of authority or argument to convince us that the classification...was illegal
or unconstitutional." The court noted that Fraidin based its analysis on an
interpretation of the statute suggested during this time frame by Collier on
Bankruptcy. While going to great lengths not to disagree with the "able author of
the text of that valuable book," the Ganaposki court refused to take the commentary
"as a suggestion to the courts to make an addition to the legislation as it was
written by Congress." The court relied on other scholarly authority in declaring it
did not have the authority to judicially rewrite the statute. One of the foremost
proponents of the doctrine of judicial restraint in the 20th century, former Harvard
law professor and U.S. Supreme Court Associate Justice Felix Frankfurter, in his
work on Reading of Statutes,<a href="#21" name="21a">21</a> explained that "[a]n omission at the time of
enactment, whether careless or calculated, cannot be judicially supplied; however, much
later wisdom may recommend the inclusion." Again, following Newman, the Ganaposki

court denied the motion to dismiss.

<h3>The Modern Era</h3>

The statute of limitations for concealment was, of course, later amended to
clarify that it begins to run when a discharge is granted or denied. However, more
than half a century after the courts first began to struggle with deciding what
limitations period applies in concealment prosecutions when the bankruptcy court has not
ruled on the bankrupt's discharge, the same question remains unanswered by Congress.
If a corporate debtor conceals assets in a liquidation, or a debtor dismisses his
or her case without the entry of a discharge, the triggering event will not have
occurred. As the foregoing authority makes clear, one possible consequence of this
course of events would be that the crime would not be governed by any limitations
period.

In deciding when a statute of limitations begins to run in a given case, the
U.S. Supreme Court has explained that the analysis must be guided by several
considerations.<a href="#22" name="22a">22</a> On one hand, criminal limitations statutes are to be liberally
interpreted in favor of repose.<a href="#23" name="23a">23</a> On the other hand, statutes of limitations normally
begin to run when the crime is complete,<a href="#24" name="24a">24</a> but should not be extended except as
otherwise expressly provided by law.<a href="#25" name="25a">25</a> Because Congress has defined concealment as
an ongoing offense, the authority of the courts to judicially craft a limitations
period other than the ones set forth in the statute is suspect, as noted by the
majority of the district courts that addressed the similar interpretation issue in the
1940s.

The Fraidin court may, however, have been on the right track with its equal
protection analysis, but without an established body of law to back it up. It can
be argued the principles of equal protection would be violated by an interpretation of
the concealment statute of limitations that allows defendants in some cases to be
prosecuted ad infinitum, while limiting the authority of the state to prosecute others
to five years from the entry or denial of the discharge. Social and economic legislation
that employ suspect classifications or impinge on fundamental rights must be invalidated
under the equal protection component of the Fifth Amendment when the legislative means
are not rationally related to a legitimate government purpose.<a href="#26" name="26a">26</a> While Congress has
a legitimate purpose in combating bankruptcy crimes, the government would, in the face
of an equal-protection challenge, have to articulate a rational reason for the two
classes that relates to this purpose. It could be argued that debtors who stay in
bankruptcy long enough to have discharge questions litigated have subjected themselves to
the jurisdiction of the courts and scrutiny of the trustee that would tend to ferret
out acts of concealment, while those who employ the bankruptcy process for a short
period conceal assets, and then dismiss the case before discharge questions that can be
addressed have hindered the ability of the system to uncover such fraud, and therefore
they should not be entitled to the benefits of the limitations period. Upon dismissal,
the bankruptcy court, panel trustee, U.S. Trustee and creditors would no longer be
able to use the civil bankruptcy process to combat acts of fraud perpetrated against the
system. Neither the statute, case law nor legislative history weigh in on this debate.

Notwithstanding the debate during the 1940s, the modern trend is for the courts
to hold that the dismissal of the case, or such similar event that prevents the entry
or denial of discharge, begins the running of the limitations period.<a href="#27" name="27a">27</a> The fact
that there is little modern case law on the subject suggests that prosecutors have
likely been cautious in their charging decisions to stay safely within the most
conservative limitations period, which is a sound approach. While practical, this
approach is not based on the text of the statute. A text-based alternative might
be to apply the general five-year statute of limitations when the triggering events
of granting or denial of the discharge have not occurred, but apply it from the point
when the last act of concealment occurred, or the last opportunity the debtor had to
disclose the property while the bankruptcy was pending. After the case has been
closed, the concealment could be considered to have succeeded (although a case can
likely be reopened to administer fraudulently concealed assets).

<h3>Conclusion</h3>

Crooked debtors—and others—who conceal assets from a bankruptcy estate should take
no solace from the foregoing discussion. It is clear that Congress intended to extend
the time period in which they can be prosecuted for such crimes beyond the limitations
period set for most crimes. Further, persons who commit such crimes and attempt to
avoid prosecution are subject to an even longer limitations period.

Persons who attempt to flee in an effort to thwart the efforts of federal
authorities to prosecute them for defrauding the bankruptcy system should consider the
fact that engaging in such conduct will toll the limitations period. Section 3290
of Title 18 provides that "[n]o statute of limitations shall extend to any person
fleeing from justice." Thus, when a defendant flees from justice, the statute of
limitations is tolled. In Streep v. United States, the U.S. Supreme Court
explained what it means to "flee justice" within the scope of the tolling statute:

In order to constitute a fleeing from justice, it is not necessary that the
course of justice should have been put in operation by the presentment of an
indictment by a grand jury, or by the filing of an information by the attorney
for the government, or by the making of a complaint before a magistrate. It
is sufficient that there is a flight with the intention of avoiding being
prosecuted, whether a prosecution has or has not been actually begun.<a href="#28" name="28a">28</a>

The case law makes it clear that whether or not a warrant has been issued at the
time of a defendant's flight is not determinative. Rather, the focus is on the
defendant's intent to avoid prosecution.

In cases when no discharge has been granted or denied, there is more than one
interpretation of the statute of limitations that governs prosecutions for concealment of
property from a bankruptcy estate. Congress should consider clearing up the uncertainty
in the law that has existed for more than half a century. Until it does so,
dishonest debtors and the federal prosecutors who prosecute them have yet one more
issue over which to wage war.

Because most efforts to defraud the bankruptcy system can be charged as a violation
of more than a single statute, and prosecutors can consider a range of offenses when
making their charging decisions, they should keep both statutes of limitations in mind.
For example, the general five-year statute of limitations will apply for false
statement or false declarations, and may be close to running out before the concealment
offense is established through investigation. As soon as possible after opening the
case, the prosecutor should determine when the limitations period will run on the
various charges under consideration, and schedule the investigation and prosecution in
order to preserve as much of the case as possible.

<hr>
<h3>Footnotes</h3>

<a name="1">1</a> Mr. Gaumer received his J.D. in 1989 from Washington University, his M.A. in 1986 in sociology and his B.A. in 1984
in journalism from Eastern Illinois University. He is a former chair of South Dakota Bankruptcy Fraud Task Force (1992-01) and
a former law clerk to Hon. Frank W. Koger, U.S. Bankruptcy Judge, W.D. Mo. <a href="#1a">Return to article</a>

<a name="2">2</a> The views expressed in this article are solely those of the author and should not be attributed to the U.S. Department of Justice,
the U.S. Attorney for the Southern District of Iowa, or any other person or entity associated with him. <a href="#2a">Return to article</a>

<a name="3">3</a> <a href="http://www.westlaw.com/find/default.asp?rs=CLWP2.1&vr=1.0&cite=… Securities Corp. v. Donaldson, 89 U.S. 304, 314 (1945)</a> (Jackson, J.). <a href="#3a">Return to article</a>

<a name="4">4</a> <a href="http://www.westlaw.com/find/default.asp?rs=CLWP2.1&vr=1.0&cite=… States v. Thompson, 98 U.S. 486, 489 (1878)</a>. <a href="#4a">Return to article</a>

<a name="5">5</a> <a href="http://www.westlaw.com/find/default.asp?rs=CLWP2.1&vr=1.0&cite=… v. New York Cent. R.R. Co., 380 U.S. 424, 428 (1965)</a>. <a href="#5a">Return to article</a>

<a name="6">6</a> <a href="http://www.westlaw.com/find/default.asp?rs=CLWP2.1&vr=1.0&cite=… Securities Corp. v. Donaldson, 325 U.S. 304, 314 (1945)</a> (citation omitted). <a href="#6a">Return to article</a>

<a name="7">7</a> As late as 1999, at least, Wyoming apparently had no time limitations on criminal prosecutions. <a href="http://www.westlaw.com/find/default.asp?rs=CLWP2.1&vr=1.0&cite=… v. Greenburgh Central
High School, 167 F.3d 784. 789 n. 4 (2nd Cir. 1999)</a>, citing <a href="http://www.westlaw.com/find/default.asp?rs=CLWP2.1&vr=1.0&cite=… v. State, 909 P.2d 1344, 1348
(Wyo. 1996)</a>. <a href="#7a">Return to article</a>

<a name="8">8</a> See, e.g., <a href="http://www.westlaw.com/find/default.asp?rs=CLWP2.1&vr=1.0&cite=… U.S.C. §152(2)</a>,(3),(4),(5),(6),(8) and (9) and §157. <a href="#8a">Return to article</a>

<a name="9">9</a> To be within the limitations period, a conspiracy charge requires proof that (1) the conspiracy must still have been ongoing within
the five-year period preceding the indictment, and (2) "at least one overt act in furtherance of the conspiratorial agreement [must have
been] performed within that period." <a href="http://www.westlaw.com/find/default.asp?rs=CLWP2.1&vr=1.0&cite=… v. United States, 353 U.S. 391, 396-97 (1957)</a> ("[T]he crucial question in
determining whether the statute of limitations has run is the scope of the conspiratorial agreement, for it is that which determines both the
duration of the conspiracy, and whether the act relied on as an overt act may properly be regarded as in furtherance of the conspiracy.").

See, also, <a href="http://www.westlaw.com/find/default.asp?rs=CLWP2.1&vr=1.0&cite=… v. Elliott, 225 U.S. 392, 401 (1912)</a> ("[In the case of an alleged conspiracy,] the period of
limitations must be computed from the date of the last [overt act] of which there is an appropriate allegation and proof." (internal quotation
marks omitted)). <a href="#9a">Return to article</a>

<a name="10">10</a> <a href="http://www.westlaw.com/find/default.asp?rs=CLWP2.1&vr=1.0&cite=… States v. Knoll, 16 F.3d 1313 (2nd Cir. 1994)</a>. <a href="#10a">Return to article</a>

<a name="11">11</a> Fed. R. Bankr. P. 4004; <a href="http://www.westlaw.com/find/default.asp?rs=CLWP2.1&vr=1.0&cite=… U.S.C. §727</a>. <a href="#11a">Return to article</a>

<a name="12">12</a> In a case where a corporate debtor converted from a chapter 11 to a chapter 7, the Eleventh Circuit has held that the limitations
period runs from the date the case was converted, which was the last opportunity for the corporate debtor to obtain a chapter 11 discharge. <a h="">

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Journal Authors

Craig Peyton Gaumer

Journal Date

Thursday, November 1, 2001 - 12:00