from one provision to the next[1]—we are highly skeptical that Congress distinguished between governments in the way petitioners suggest.
2
Undaunted, petitioners note that Congress has historically treated various types of governments differently for purposes of bankruptcy law. Tr. of Oral Arg. 14–15; Reply Brief 21. They assert that, in the decades leading up to the Bankruptcy Code’s enactment, bankruptcy law afforded certain benefits to “ ‘the United States or any State or any subdivision thereof,’ ” leaving out entities that did not fall into one of those enumerated categories. Reply Brief 21 (quoting §64(a)(4), 52 Stat. 874).
Even if petitioners’ understanding of this history is correct, they have failed to demonstrate that the Code carried forward any such differential treatment. Congress ushered in “a new, unprecedented era in bankruptcy practice” when it enacted the Code in 1978. 1 W. Norton, Bankruptcy Law and Practice §1:9, p. 1-17 (3d ed. 2023); Northern Pipeline Constr. Co. v. Marathon Pipe Line Co., 458 U. S. 50, 52–53 (1982) (plurality opinion) (describing the Code as “a comprehensive revision of the bankruptcy laws”). Both §101(27)’s definition of “governmental unit” and §106(a)’s abrogation of sovereign immunity were some of the many changes Congress made. The prior statute did not provide a general definition for governmental entities, much less in-
- ↑ For example, the Code defines “domestic support obligation” to include debts “owed to or recoverable by” spouses as well as “governmental unit[s].” §101(14A). And the term “person” covers an “individual, partnership, and corporation,” as well as a “governmental unit that … acquires an asset from a person … as a result of the operation of a loan guarantee agreement” or “as receiver or liquidating agent of a person.” §101(41). The main feature that sets “governmental unit[s]” apart from other entities mentioned in these definitions is their governmental nature.
