In Re James C. Pearson, Ida J. Pearson, Debtors. James C. Pearson, Ida J. Pearson v. United States

KOZINSKI, Circuit Judge:

This ease presents an issue of first impression in this circuit: Is the United States immune from suit for money damages for violating the Bankruptcy Code’s automatic stay, 11 U.S.C. § 362(a)?

A. Bankruptcy Code section 106(c) provides that “governmental units” are *1216bound by any code provision that “contains ‘creditor’, ‘entity’, or ‘governmental unit’ ... [and by] a determination of the court of an issue arising under such a provi-sion_” 11 U.S.C. § 106(c) (emphasis added). The Code’s automatic stay provision, in turn, operates against all “entities,” 11 U.S.C. §…