Jones v. Randle

Judicial estoppel precludes someone for asserting an ownership interest in property that was undisclosed during previous bankruptcy proceedings if that person derived a benefit from not disclosing their ownership interest before.

Jones appealed the trial court’s grant of summary judgment and the trial court’s conclusion that judicial estoppel barred Jones from asserting any ownership interest in certain property because Jones failed to disclose her ownership interest in two previous bankruptcy proceedings. The Court held that judicial estoppel precludes a debtor who invokes the protection of the bankruptcy court and purports to disclose all of its assets from later asserting a claim that existed, but was undisclosed, at the time of the bankruptcy. In addition, to be judicially estopped, a litigant must have derived a benefit from the nondisclosure itself, as opposed to deriving a benefit from the bankruptcy proceeding in general. The Court held that Jones did not derive a benefit from the nondisclosure. Reversed and remanded.