On May 26, 2015, the US Supreme Court held in Wellness International Network, Ltd. v. Sharif that Article III of the Constitution permits bankruptcy judges to adjudicate Stern claims, or claims for which parties are constitutionally entitled to adjudication by an Article III judge, with the parties' knowing and voluntary consent (No. 13-935, (S. Ct. May 26, 2015)).

This case arose from long-running efforts of Wellness International Network to collect on a judgment awarding Wellness over $650,000 in attorneys' fees from Richard Sharif. Sharif filed for Chapter 7 bankruptcy in February 2009 and listed Wellness as a creditor. After continued discovery abuses from Sharif, the bankruptcy court denied Sharif's request to discharge his debts and entered a default judgment against him in a separate adversary proceeding with Wellness. There, the court declared that the previously undisclosed assets held by a trust administered by Sharif were part of his bankruptcy estate. Sharif appealed to the district court.

During this time, the Supreme Court held in Stern v. Marshall that bankruptcy courts lack the constitutional authority to enter final judgment on certain claims for which litigants are constitutionally entitled to an Article III adjudication ("core" claims) (131 S. Ct. 2594 (2011)). The Supreme Court concluded that although the bankruptcy court had been given the statutory authority under 28 U.S.C. § 157 to make final decisions on such core claims, it does not have the authority to do so under Article III. Article III therefore prevents bankruptcy courts from entering final judgment on claims that seek only to augment the bankruptcy estate and would otherwise exist without regard to any bankruptcy proceeding.

In light of Stern, Sharif filed a motion for leave to file a supplemental brief to address Stern's impact on the proceedings, but the district court denied the motion as untimely and affirmed the bankruptcy court decision. The US Court of Appeals for the Seventh Circuit affirmed in part and reversed in part, concluding that under Stern, the bankruptcy court lacked constitutional authority to enter final judgment on the claim that the trust was part of Sharif's bankruptcy estate.

The Supreme Court reversed, holding that Article III is not violated when the parties knowingly and voluntarily consent to adjudication by a bankruptcy judge. The Court emphasized that Article III's guarantee of an impartial and independent federal adjudication is a personal right and subject to waiver. Allowing bankruptcy courts to decide Stern claims by consent would therefore neither threaten the institutional integrity of the Judicial Branch nor usurp the constitutional prerogatives of Article III courts. Stern does not compel a different result, the Court held, because the litigant in that case did not consent to the resolution of the claim in a non-Article III forum.

The Court also rejected any argument that the consent to adjudication by a bankruptcy court must be express. Rather, the implied consent standard articulated in Roell v. Withrow should be followed (123 S. Ct. 1696 (2003)). Consent, however, must still be knowing and voluntary. As a result, the Supreme Court held that Article III permits bankruptcy courts to decide Stern claims submitted to them by consent, and remanded the case to the Seventh Circuit to determine whether Sharif demonstrated the requisite knowing and voluntary consent.