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Abstract: This issue of Bankruptcy Law Letter traces the history of the Barton Doctrine, showing how, over time, it has taken on increasingly expansive applications. Although the doctrine undeniably began as one of subject matter jurisdiction, courts have since expanded its use on more amorphous grounds. These expansions result in courts trying to make sense of competing justifications for applying the doctrine to fact patterns that are far afield from those initially contemplated in the Barton case.
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