Tenth Circuit -- Satterfield v. Malloy

Suit cannot be brought against a bankruptcy trustee for malfeasance without the permission of the Bankruptcy Court.

Allegation of improper motive does not allow suit under an ultra vires exception to this rule.

No private tort exception to the rule.

Rule applies even after the case has been closed.

Statutory cause of action inapposite.

Satterfield v. Malloy