One hundred forty years ago, the U.S. Supreme Court held in Barton v. Barbour, 104 U.S. 126, 128 (1881), that before suit is brought against a receiver, leave of court by which he was appointed must be obtained. The so-called Barton doctrine has since been expanded to also include bankruptcy trustees and other fiduciaries, but a recent ruling by the Eleventh Circuit Court of Appeals has dramatically curtailed its lifespan. On June 15, the Eleventh Circuit issued its opinion in Chua v. Ekonomou, No. 20-12576, holding that once a receivership or bankruptcy proceeding is concluded, a litigant no longer needs to obtain permission from the receivership or bankruptcy court before initiating suit against the court-appointed receiver or trustee. By doing so, the Eleventh Circuit has also created a split among the circuits, creating possible jeopardy for receivers and trustees and paving the way for a possible return of the Barton doctrine to the U.S. Supreme Court