Uploaded March 2025 | Updated September 2026, 2 weeks ago
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Matter of Hendrix
United States Court of Appeals for the Seventh Circuit
986 F.2d 195 (1993)
Attorneys have a duty to be zealous advocates for their clients, but attorneys also owe a duty of candor to the courts in which they appear. Sometimes, these conflicting duties can strand a lawyer between a rock and a hard place.
Matter of Hendrix demonstrates how not to resolve this dilemma. Daniel Hendrix injured Sarah Page in a car accident. The Atlanta Casualty Company was Hendrix's insurer.
Page filed a personal injury suit against Hendrix in Indiana state court. Sometime thereafter, Hendrix declared chapter seven bankruptcy.
Hendrix added Page to the list of creditors he filed with the bankruptcy court.
Page didn't file a claim in the bankruptcy proceeding.
The bankruptcy court granted Hendricks a discharge from his debts to the listed creditors.
The discharge acted as an injunction prohibiting Hendricks's creditors from suing to collect his debts to them. An attorney nominally representing Hendrix, but actually representing Atlanta Casualty, filed a motion for summary judgment in Page's Indiana case against Hendrix.
The trial court granted the motion and entered a final judgment for Hendrix.
That court reasoned that the bankruptcy discharge barred Page from trying to collect any debt Hendricks owed her via a state court lawsuit.
Page then moved to reopen the bankruptcy proceeding. Page asked the bankruptcy court to modify the discharge so that she could ask the Indiana State Court to allow her to proceed against Atlanta Casualty.
The bankruptcy court granted the motion.
The district court affirmed. Atlanta Casualty appealed to the Seventh Circuit.
After Atlanta Casualty filed its notice of appeal, but long before either party filed appellate briefs, the Seventh Circuit issued an opinion in In Ray Shaundel. Shaundel held that a discharge in bankruptcy doesn't preclude a suit against a debtor's insurer to collect insurance proceeds. This decision effectively resolved Atlanta Casualty's appeal in Page's favor, but neither Atlanta Casualty nor Page cited Shondell to the seventh circuit.
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Get more case briefs explained with Quimbee. Quimbee has over 42,700 case briefs (and counting) keyed to 988 casebooks ► quimbee.com/case-briefs-overview
Matter of Hendrix
United States Court of Appeals for the Seventh Circuit
986 F.2d 195 (1993)
Attorneys have a duty to be zealous advocates for their clients, but attorneys also owe a duty of candor to the courts in which they appear. Sometimes, these conflicting duties can strand a lawyer between a rock and a hard place.
Matter of Hendrix demonstrates how not to resolve this dilemma. Daniel Hendrix injured Sarah Page in a car accident. The Atlanta Casualty Company was Hendrix's insurer.
Page filed a personal injury suit against Hendrix in Indiana state court. Sometime thereafter, Hendrix declared chapter seven bankruptcy.
Hendrix added Page to the list of creditors he filed with the bankruptcy court.
Page didn't file a claim in the bankruptcy proceeding.
The bankruptcy court granted Hendricks a discharge from his debts to the listed creditors.
The discharge acted as an injunction prohibiting Hendricks's creditors from suing to collect his debts to them. An attorney nominally representing Hendrix, but actually representing Atlanta Casualty, filed a motion for summary judgment in Page's Indiana case against Hendrix.
The trial court granted the motion and entered a final judgment for Hendrix.
That court reasoned that the bankruptcy discharge barred Page from trying to collect any debt Hendricks owed her via a state court lawsuit.
Page then moved to reopen the bankruptcy proceeding. Page asked the bankruptcy court to modify the discharge so that she could ask the Indiana State Court to allow her to proceed against Atlanta Casualty.
The bankruptcy court granted the motion.
The district court affirmed. Atlanta Casualty appealed to the Seventh Circuit.
After Atlanta Casualty filed its notice of appeal, but long before either party filed appellate briefs, the Seventh Circuit issued an opinion in In Ray Shaundel. Shaundel held that a discharge in bankruptcy doesn't preclude a suit against a debtor's insurer to collect insurance proceeds. This decision effectively resolved Atlanta Casualty's appeal in Page's favor, but neither Atlanta Casualty nor Page cited Shondell to the seventh circuit.
Want more details on this case? Get the rule of law, issues, holding and reasonings, and more case facts here: quimbee.com/cases/matter-of-hendrix
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Subscribe to our YouTube Channel ► youtube.com/subscription_center?add_user=QuimbeeDotCom
Quimbee Case Brief App ► quimbee.com/case-briefs-overview
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