ron pair enterprises argued october decided february respondent filed petition chapter bankruptcy code code government filed proof prepetition claim unpaid withholding social security taxes penalties prepetition interest claim perfected tax lien property owned respondent respondent ensuing reorganization plan provided full payment claim provide postpetition interest government objected contending code allows holder oversecured claim recover addition prepetition amount claim interest claim reasonable fees costs charges provided agreement claim arose allowed recovery postpetition interest since property securing claim value greater amount principal debt bankruptcy overruled objection district reversed appeals reversed district holding codified standard allowed postpetition interest oversecured claim lien claim consensual nature held section entitles creditor receive postpetition interest nonconsensual oversecured claim allowed bankruptcy proceeding pp natural reading phrase shall allowed holder claim interest claim reasonable fees costs charges provided agreement claim arose entitles holder oversecured claim postpetition interest addition holder secured claim pursuant agreement right specified fees costs charges recovery postpetition interest unqualified whereas recovery fees costs charges allowed reasonable provided agreement claim arose therefore absence agreement postpetition interest added recovery available reading also mandated grammatical structure since phrase interest claim set aside commas separated reference fees costs charges conjunctive words phrase stands independent language follows pp allowing postpetition interest nonconsensual oversecured liens contravene intent code framers conflict section code important state federal interest legislative history suggest contrary view pp significant reason congress intended policy reason compel consensual nonconsensual liens treated differently allowing postpetition interest section language clearly directs postpetition interest paid oversecured claims midlantic national bank new jersey dept environmental protection kelly robinson distinguished pp practice denying postpetition interest holders nonconsensual liens allowing holders consensual liens exception exception oversecured claims rule running interest ceased bankruptcy petition filed recognized courts often depended particular circumstances fact never clearly acknowledged relied upon refusal courts appeals apply oversecured claim exception oversecured federal tax claim counsels concluding limitation well recognized also arguing considering limitation clear rule facts cases limited exception cases rule never extended forms nonconsensual liens cases recognized guide bankruptcy trustee exercise powers particular circumstances case pp blackmun delivered opinion rehnquist white scalia kennedy joined filed dissenting opinion brennan marshall stevens joined post deputy solicitor general wallace argued cause briefs solicitor general fried assistant attorney general rose alan horowitz wynette hewett martha brissette william cohen argued cause respondent brief michael traison george kaufmann peter morgan lawrence garr filed brief refining amicus curiae urging affirmance justice blackmun delivered opinion case must decide narrow statutory issue whether bankruptcy code supp iv entitles creditor receive postpetition interest nonconsensual oversecured claim allowed bankruptcy proceeding conclude therefore reverse judgment appeals respondent ron pair enterprises filed petition reorganization chapter bankruptcy code may bankruptcy eastern district michigan government filed timely proof prepetition claim comprised assessments unpaid withholding social security taxes penalties prepetition interest claim perfected tax lien property owned respondent respondent first amended plan reorganization filed october provided full payment prepetition claim provide postpetition interest claim government filed timely objection claiming allowed recovery postpetition interest since property securing claim value greater amount principal debt bankruptcy hearing parties stipulated claim oversecured subsequently overruled government objection government appealed district eastern district michigan reversed bankruptcy judgment concluding plain language entitled government postpetition interest appeals sixth circuit turn reversed district directly ruling language ambiguous reasoned reference law appropriate order better understand context provision drafted therefore language went note law general rule postpetition interest oversecured prepetition claim allowable lien consensual nature light practice lack legislative history evincing intent change standard held codified standard postpetition interest allowable consensual claims result direct conflict view appeals fourth circuit see best repair views courts granted certiorari resolve conflict ii section enacted part extensive revision bankruptcy laws governs definition treatment secured claims claims creditors estate secured lien property estate interest subsection provides claim secured extent value property lien fixed remainder claim considered unsecured subsection concerned specifically oversecured claims claim amount less value property securing thus claim secured lien property value claim oversecured provided trustee costs preserving disposing property less section allows holder oversecured claim recover addition prepetition amount claim interest claim reasonable fees costs charges provided agreement claim arose question us today arises two types secured claims voluntary consensual secured claims created agreement debtor creditor called security interest code supp iv involuntary secured claims judicial statutory lien see supp iv fixed operation law require consent debtor claim respondent estate latter kind prior passage code courts appeals drew distinction two types purposes determining postpetition interest question must answer whether code recognizes enforces distinction whether congress intended oversecured claims treated way purposes postpetition interest iii initially worth recalling congress worked formulation code nearly decade intended modernize bankruptcy laws see report result made significant changes substantive procedural laws bankruptcy see northern pipeline construction marathon pipe line plurality opinion particular congress intended significant changes current law treatment secured creditors secured claims report substantial overhaul system appropriate realistic expect congress explained particularity step took rather long statutory scheme coherent consistent generally need inquire beyond plain language statute task resolving dispute meaning begins inquiries must begin language statute landreth timber landreth case also inquiry end statute language plain sole function courts enforce according terms caminetti language us expresses congress intent postpetition interest available sufficient precision reference legislative history practice hardly necessary relevant phrase shall allowed holder claim interest claim reasonable fees costs charges provided agreement claim arose claim refers oversecured claim natural reading phrase entitles holder oversecured claim postpetition interest addition gives one secured claim created pursuant agreement right reasonable fees costs charges provided agreement recovery postpetition interest unqualified recovery fees costs charges however allowed reasonable provided agreement claim arose therefore absence agreement postpetition interest added recovery available reading also mandated grammatical structure statute phrase interest claim set aside commas separated reference fees costs charges conjunctive words result phrase interest claim stands independent language follows nterest claim part list made fees costs charges joined following clause final provided agreement modifies well see best repair language punctuation congress used read way plain language statute two types recovery distinct plain meaning legislation conclusive except rare cases literal application statute produce result demonstrably odds intentions drafters griffin oceanic contractors cases intention drafters rather strict language controls ibid clear allowing postpetition interest nonconsensual oversecured liens contravene intent framers code allowing interest conflict section code important state federal interest contrary view suggested legislative history respondent articulated discern significant reason congress intended policy reason compel two types secured claims treated differently allowing postpetition interest respondent urges practice drew distinction consensual nonconsensual liens purpose determining entitlement postpetition interest congress failure repudiate distinction requires us enforce respondent view view appeals midlantic national bank new jersey dept environmental protection kelly robinson require disagree midlantic held code provides trustee may abandon property estate burdensome estate give trustee authority violate state health safety laws abandoning property containing hazardous wastes reaching conclusion noted according doctrine trustee authority dispose property limited order protect legitimate state federal interests rest solely even primarily presumption continuity practice rather concluded contrary result render abandonment doctrine inconsistent provisions code embody principle trustee carte blanche ignore nonbankruptcy law also recognized outcome sought departure practice also extraordinary exemption nonbankruptcy law requiring clearer expression congressional intent relied well congress repeated emphasis environmental legislation goal protecting environment toxic pollution quoting chemical manufacturers assn natural resources defense council put simply looked practice interpretive assistance appeared literal application statute demonstrably odds intentions drafters griffin oceanic contractors similar issue presented kelly robinson supra held restitution obligation imposed part state criminal sentence dischargeable bankruptcy reached conclusion interpreting code preserv ing discharge condition state criminal imposes part criminal sentence noted code provision subject interpretation considered legislative history practice aid interpretation determining congress intended depart practice regard rely pale presumption effect concluded practice animated deep conviction federal bankruptcy courts invalidate results state criminal proceedings source basic principle federalism interest administering criminal justice systems free federal interference one powerful considerations influence considering equitable types relief kelly midlantic practice significant reflected policy considerations great longevity importance kelly midlantic make clear appropriate case must determine whether congress expressed intent change interpretation judicially created concept enacting code midlantic kelly suggest limits may constitute appropriate case decisions concerned statutory language least degree open interpretation involved situation bankruptcy law proposed interpretation clear conflict state federal laws great importance present case contrast language question clearer language issue midlantic kelly written directs postpetition interest paid oversecured claims addition natural interpretation statutory language conflict significant state federal interest aspect code although payment postpetition interest arguably somewhat tension desirability paying creditors uniformly practicable congress expressly chose create alleged tension reason suspect congress mean language statute says even saw need turn practice case little assistance practice denying postpetition interest holders nonconsensual liens allowing holders consensual liens exception exception recognized courts often dependent particular circumstances certainly type rule assume congress aware enacting code significance congress taken steps enacting statutory language contrary indeed rule running interest ceased bankruptcy petition filed see sexton dreyfus two exceptions rule recognized practice first allowed postpetition interest debtor ultimately proved solvent second allowed dividends interest earned securities held creditor collateral applied postpetition interest see city new york saper neither exceptions relevant case third exception doubtful provenance exception oversecured claims least one appeals refused apply exception harrington uncertainty among courts recognize whether ever done bass see vanston bondholders protective committee green issue case oversecured claim exception per se exception exception several courts appeals refused apply oversecured claim exception oversecured federal tax claim see harrington holding even general exception oversecured claims apply tax liens bass kerber packing see also boston maine municipal property tax claim cert denied sub nom city cambridge meserve see parchem supp allowing postpetition interest tax claim appeal dism upon stipulation ross nursing home edny refusal apply exception appeals thought constituted judicially created rule fact never clearly acknowledged relied upon limitation exception counsels concluding limitation well recognized also arguing considering limitation clear rule fact cases limited third exception cases gave weight city new york saper supra ruled postpetition interest available unsecured tax claims reasoned broad language case denied tax claims see harrington bass kerber packing rule articulated cases never extended forms nonconsensual liens obviously way read allowing postpetition interest oversecured claims except claims based unpaid taxes reason statute congress wrote simply subject reading harmonize supposed rule importantly rule cases recognized guide trustee exercise powers particular circumstances case noted touchstone decision allowance interest bankruptcy balance equities creditor creditor creditors debtor vanston bondholders protective committee green exceptions denial postpetition interest rigid doctrinal categories rather flexible guidelines developed courts exercise equitable powers insolvency proceedings boston maine none cases cited appeals doctrine anything provide bankruptcy guidance exercise equitable powers reason think congress enacting contrary standard felt need expressly repudiate contrary view view adopt today consistent congress stated intent enacting code codif creditors rights clearly case law defin ing protections secured creditor entitled means may grant protection report emphasis added whether congress took notice standard acted sufficient clarity enacting statute judgment appeals reversed ordered footnotes section amended reads allowed claim creditor secured lien property estate interest subject setoff section title secured claim extent value creditor interest estate interest property extent amount subject setoff case may unsecured claim extent value creditor interest amount subject setoff less amount allowed claim value determined light purpose valuation proposed disposition use property conjunction hearing disposition use plan affecting creditor interest extent allowed secured claim secured property value recovery subsection section greater amount claim shall allowed holder claim interest claim reasonable fees costs charges provided agreement claim arose trustee may recover property securing allowed secured claim reasonable necessary costs expenses preserving disposing property extent benefit holder claim extent lien secures claim debtor allowed secured claim lien void unless claim disallowed section title claim allowed secured claim due failure entity file proof claim section title ed supp iv thus claim secured lien property value considered secured claim extent unsecured claim see collier bankruptcy ed ection requires bifurcation partially secured undersecured claim separate independent secured claim unsecured claim components appeals fourth circuit pointed best repair congress intended limit postpetition interest consensual liens said shall allowed holder claim provided agreement claim arose interest claim reasonable fees costs charges less clear way stating closer actual language shall allowed holder claim interest claim reasonable fees costs charges provided agreement claim arose ibid seems us interpretation adopted appeals case requires statutory language read unnatural way inconsistent remainder terminology used throughout code adopting appeals view mean operative regard consensual liens holder oversecured claim arising agreement entitled added recovery portions make distinction consensual nonconsensual liens moreover congress intended apply consensual liens clarified intent using specific phrase security interest code employs refer liens created agreement supp iv congress wanted restrict application particular provision code liens used term security interest see ed supp iv see sess sess sess final version statute contained language initially introduced change legislative process shed light meaning allowance interest see generally collier bankruptcy pp neither committee reports statements managers legislation discuss question postpetition interest see report cong rec statement edwards statement deconcini section provides discharge bankruptcy affect debt fine penalty forfeiture payable benefit governmental unit compensation actual pecuniary loss rule preventing discharge criminal fines articulated promptly bankruptcy act passed see moore wd uniformly accepted time congress considering code see kelly robinson courts also distinguished two types liens nonconsensual liens often fixed entirety debtor property consensual liens usually fixed particular item property whatever merit distinction modern commercial lending practices changed unusual commercial lenders obtain lien almost debtor property congress enacting code aware see report fact took specific steps deal blanket liens household goods see hand nonconsensual liens attach broadly debtor property typical mechanic construction lien limited property improvement made see crandall hagedorn smith law manual justice justice brennan justice marshall justice stevens join dissenting decision based two distinct lines argument first concludes language bankruptcy code clear unambiguous second takes narrow view midlantic national bank new jersey dept environmental protection progeny disagree aspects opinion conclusion lead relevant portion provides shall allowed holder oversecured claim interest claim reasonable fees costs charges provided agreement claim arose concludes natural reading recovery postpetition interest unqualified ante justice frankfurter remarked time ago however notion words statute plain meaning also plain merely pernicious oversimplification monia dissenting opinion although use comma exceedingly arbitrary indefinite palmer wheat separate opinion johnson able read way comma following phrase interest claim without capricious bit punctuation newbury cafe cert pending relevant portion read follows shall allowed holder oversecured claim interest claim reasonable fees costs charges provided agreement claim arose phrase interest claim qualified phrase provided agreement claim arose nonconsensual liens accrue postpetition interest see porto rico railway light power mor several words followed clause applicable much first words last natural construction language demands clause read applicable conclusion altered fact words follow phrase interest claim words simply indicate interest accrues amount claim fees costs charges happen incurred creditor reliance comma misplaced unctuation decisive construction statute costanzo tillinghast see also barrett van pelt punctuation minor controlling element interpretation courts disregard punctuation statute need give effect otherwise appears purpose true meaning ewing burnet pet punctuation fallible standard interpret writing may resorted means fail first take instrument four corners order ascertain true meaning apparent judicially inspecting whole punctuation suffered change rule construction hesitated past change ignore punctuation legislation order effectuate congressional intent see simpson ignoring punctuation conjunction qualifying phrase modify antecedent followed comma word stephens cherokee nation ignoring punctuation qualifying phrase restrict antecedent set commas followed word although punctuation controlling provide useful confirmation conclusions drawn words statute naftalin attempts buttress interpretation suggesting reading inconsistent remaining portions make distinction consensual nonconsensual liens ante regardless read distinguish types liens phrase provided agreement claim arose certainly refers consensual liens must qualify preceding language even interpretation reasonable fees costs charges awarded provided consensual lien thus limiting postpetition interest consensual liens simply reinforces distinction already exists reason find unavailing assertion congress used phrase security interest wanted limit postpetition interest consensual liens even believed language clearer disagree conclusion midlantic counsels inferring congressional intent change bankruptcy law issue midlantic code provided fter notice hearing trustee may abandon property estate burdensome estate inconsequential value estate despite unequivocal language held authorize trustee abandon hazardous property contravention state statute regulation reasonably designed protect public health safety relying three cases one deal state laws another relevant language arguably dicta concluded bankruptcy law restrictions trustee power abandon property stated normal rule statutory construction congress intends legislation change interpretation judicially created concept makes intent specific noted followed rule particular care construing scope bankruptcy codifications citations omitted given law congress goal protecting environment unwilling assume enactment congress implicitly overturned longstanding restrictions common law abandonment power characterizes midlantic involving situation bankruptcy law proposed interpretation clear conflict state federal laws great importance ante though agree characterization think midlantic conflict state federal laws contrary intimation midlantic concer statutory language open interpretation ante language absolute terms rehnquist dissenting midlantic attempt argue otherwise nonetheless concluded clear language insufficient demonstrate specific congressional intent change law rule midlantic bankruptcy statutes deemed changed law unless indication congress thought effecting change see kelly robinson nowhere house senate reports indication language read intrusively congress intended code provision discharge state criminal sentences certain hearings testimony debate concerning consequences wasteful inimical purposes previously deemed important likely arouse public outrage quoting tva hill powell dissenting first step midlantic ascertain whether established bankruptcy practice see question easily answered prior enactment code well every appeals address question refused allow postpetition interest nonconsensual liens tax lien involved case see city new york saper kerber packing mighell bass harrington see also boston maine case allowing postpetition interest municipal tax lien cert denied sub nom city cambridge meserve order deflect line cases refers practice denying postpetition interest holders nonconsensual liens allowing holders consensual liens exception exception ante regardless labeled cf henneford silas mason catch words labels subject dangers lurk metaphors symbols must watched circumspection lest put us guard practice widespread well established practice midlantic certainly one congress aware enacting code ante denial postpetition interest nonconsensual liens based distinction types liens well equitable considerations unlike consensual liens parties voluntarily agree nonconsensual liens depend existence legislative fiat thus justification allowance postpetition interest consensual liens creditor extended credit relied upon particular security given collateral secure principal debt interest payment collateral sufficient pay contract parties abrogated bankruptcy harrington application nonconsensual liens allowance interest nonconsensual liens akin penalty debtor nonpayment taxes monetary obligations imposed law permitting postpetition interest nonconsensual liens drains pool assets detriment lower priority creditors responsible debtor inability pay avoid imposition postpetition interest see boston maine indeed acknowledges payment postpetition interest arguably somewhat tension desirability paying creditors uniformly practicable ante second step midlantic look indicia congress knew changing law see said last term improbable change existing bankruptcy rules made without even mention legislative history savings assn texas timbers inwood forest associates legislative history wholly inconclusive best repair statement history acknowledging work major change law evidence whatsoever meant allow postpetition interest nonconsensual liens assumed congress silently abrogated law kelly robinson reasons set forth respectfully dissent