Whether a court must use a specific two-factor test or a broader inquiry to determine if a debtor's omission of a claim in bankruptcy was "inadvertent or mistaken" for purposes of judicial estoppel. Specifically, the Court addresses whether the Fifth Circuit erred by limiting its inquiry to the debtor's knowledge of underlying facts and potential motive to conceal. The central issue is how the equitable nature of judicial estoppel informs the assessment of a debtor's intent.

Petitioner sought to proceed with his personal-injury action against the respondent. He argued that judicial estoppel was inappropriate because his failure to disclose the claim in his Chapter 13 bankruptcy was inadvertent. To support this, he submitted affidavits stating he believed he had fulfilled his obligations and received no monetary benefit from the nondisclosure.

Respondent sought summary judgment to dismiss the personal-injury action based on the doctrine of judicial estoppel. They argued that the failure to disclose the claim in the bankruptcy schedules constituted an implicit representation that the claim did not exist. Consequently, they contended that petitioner was barred from taking an inconsistent position by later asserting the claim in court.

The Court held that the Fifth Circuit erred by applying a rigid two-factor test to determine if a bankruptcy omission was inadvertent or mistaken. The Court noted that judicial estoppel is an "equitable doctrine" intended "to protect the integrity of the judicial process," citing *New Hampshire v. Maine*. Because it is an equitable doctrine, the Court emphasized that it "eschews mechanical rules" and "depends on flexibility," invoking *Holmberg v. Armbrecht*. The Court further reasoned that equitable inquiries must be conducted "on a case-by-case basis," considering all relevant facts and circumstances, as required by *Holland v. Florida*. The Fifth Circuit's rule was too rigid because it prohibited courts from considering any evidence of inadvertence beyond knowledge of facts or motive to conceal. The Court also found the rule too broad because a "potential motive to conceal" is almost always present when a debtor fails to disclose a claim. The Court observed that such a "near-dispositive criterion" is incompatible with a fair inquiry into whether an omission was actually a mistake. The Court assumed, without deciding, that judicial estoppel can apply in bankruptcy and that "inadvertence or mistake" can serve as an exception. The Court concluded that the Fifth Circuit artificially narrowed its inquiry by ignoring the totality of the circumstances. Accordingly, the Court vacated the judgment and remanded the case for further proceedings.

not stated.