Does the doctrine of judicial estoppel bar a debtor from pursuing a legal claim that was omitted from their bankruptcy schedules? Specifically, what standard should courts use to determine if such an omission was "inadvertent or mistaken"? Is the Fifth Circuit's two-factor test—focusing on knowledge of facts and motive to conceal—legally sufficient?

• The omission of the personal-injury claim from the bankruptcy schedules was inadvertent, as he believed he had done everything necessary after informing his bankruptcy counsel.
• He received no monetary or other benefit from the nondisclosure of the claim.
• The Fifth Circuit's rigid test for inadvertence is too narrow and fails to account for the equitable nature of the judicial estoppel doctrine.

• The failure to disclose the claim in an open bankruptcy proceeding constitutes an "implicit representation" that the claim does not exist.
• Under Fifth Circuit precedent, the omission was not inadvertent because the petitioner knew the underlying facts of the car accident.
• The petitioner had a hypothetical motive to conceal the claim to avoid the possibility of having to pay interest on his debts.

• The Court held that to determine if an omission of a claim in bankruptcy was inadvertent or mistaken for purposes of judicial estoppel, courts must look to the "totality of the circumstances" surrounding the omission.
• The Court identified judicial estoppel as an "equitable doctrine" intended to "protect the integrity of the judicial process" and prevent parties from "deliberately changing positions," citing *New Hampshire v. Maine*.
• The Court reasoned that equity "eschews mechanical rules; it depends on flexibility," invoking *Holmberg v. Armbrecht*.
• Because the inquiry is equitable, the Court noted that courts must act "on a case-by-case basis," considering all relevant facts and circumstances per *Holland v. Florida*.
• The Court found the Fifth Circuit's rule too rigid because it limited the inquiry to only two factors: whether the debtor knew the underlying facts and whether there was a potential motive to conceal.
• The Court further found the Fifth Circuit's rule too broad because a "potential motive" to conceal is "almost always met," effectively creating a "one-size-fits-all test" that views nearly every omission as purposeful.
• The Court concluded that a "near-dispositive criterion" is a poor fit for a fair inquiry into whether an omission is actually the result of inadvertence or mistake.
• The Court vacated the judgment of the Fifth Circuit and remanded the case for further proceedings.