of this title, except a stockbroker or a commodity broker, and a railroad may be a debtor under chapter 11 of this title." In turn, Section 109(b) provides that "[a] person may be a debtor under chapter 7 of this title" as long as the person is not a railroad, insurance company, or bank or similar financial institution. Nothing in the text of the Code requires that only businesses or individuals engaged in a business can file for chapter 11 reorganization. Given the great care with which Congress enumerated those who can and cannot receive protection under each chapter, the Court was "loath to infer the exclusion of certain classes of debtors from the protections of Chapter 11." Turning to the legislative history of the then-current version of the Bankruptcy Code, the Court acknowledged that a Senate report showed that Congress anticipated that businesses would be the most common parties to file under chapter 11. However, this did not show that only businesses could permissibly file under chapter 11. Likewise, the Court considered the ultimate purposes of the various chapters of the Code, one of which is "maximizing the value of the bankruptcy estate"; because a chapter 11 reorganization plan must be approved by creditors or must provide that creditors "will receive not less than they would receive under a Chapter 7 liquidation," denying chapter 11 protection to individuals would not advance Congress' overall purpose. Finally, the Court considered the possibility that if chapter 11 were held to apply to individuals, an individual could be subjected to an involuntary chapter 11 case leading to "debt peonage," a form of involuntary servitude). (Although chapter 13 bankruptcy petitions are always voluntary, a chapter 11 case can be commenced by creditors.) However, the Court observed, if a debtor chose not to cooperate in a chapter 11 case, the bankruptcy court could simply to convert the case to a chapter 7 liquidation. Justice Stevens' dissent Justice Stevens dissented, acknowledging that "[t]he Court's reading of the statute is plausible," given that the statutory language does not expressly exclude non-business debtors from chapter 11 and the Senate Report language quoted in the majority opinion. Nonetheless, Stevens disagreed with the Court's conclusion, opining that chapter 11 of the Bankruptcy Code was intended to apply to business debtors only. In support of his view, Stevens noted that chapter 11 is entitled "Reorganization," and that the statutory language of