In re Sinclair
United States Court of Appeals for the Seventh Circuit
870 F.2d 1340 (1989)
The Sinclairs (plaintiffs), family farmers, filed a Chapter 11 bankruptcy petition in 1985; in 1986 Congress added Chapter 12, providing special benefits to farmers, but the enacting statute specified the new provisions didn't apply to cases commenced before the Act's effective date. A committee report accompanying the legislation suggested existing Chapter 11 and 13 petitions should be converted to Chapter 12 when equitable; the Sinclairs sought to convert their pre-existing petition on this basis, but the bankruptcy court and district court denied the request, and the Sinclairs appealed.
Whether the clear text of a statute barring application to pre-enactment cases controls over conflicting legislative history suggesting a different, more permissive interpretation.