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Creditor that Filed an Excessive Claim Draws Court’s Rebuke and Possible Sanctions

This post is about a junkyard, hogs getting slaughtered, and a bankruptcy judge poised to sanction a creditor and her counsel. The message from the case to would-be claimants in other cases is simple: do not “overreach.” In...more

Substantial Contribution: A New Decision from the Third Circuit

It’s often hard to persuade a bankruptcy court to grant a motion for substantial contribution. Any attorney thinking about making a motion should first ask herself two questions. First, has my work benefitted both my client...more

Second Circuit Reaffirms that Debtor Can Obtain Refund for Non-Uniform Bankruptcy Fees

We have previously blogged about Siegel v. Fitzgerald, the Supreme Court decision last June that invalidated the 2018 difference in fees between bankruptcy cases filed in Bankruptcy Administrator judicial districts and U.S....more

Crypto Company FTX Files Massive Bankruptcy in Delaware

Another domino has fallen.  Earlier this year, we wrote about the challenges facing the crypto industry that resulted in the bankruptcy filings of Three Arrows Capital, Celsius Network, and Voyager Digital. We noted that...more

New SDNY Decision on Administrative Priority for Executory Contracts

To encourage parties to transact with debtors in bankruptcy, the Bankruptcy Code in corporate bankruptcies provides highest priority to “administrative expenses,” which include “the actual, necessary costs and expenses of...more

Court Says Creditor Can Sue a Liquidating Trustee without Prior Permission

A bankruptcy court ruled that a creditor didn’t need to seek derivative standing to sue a liquidating trustee.  The creditor, himself a trustee of the debtor’s employee stock-option plan, had standing to sue without prior...more

Supreme Court Refuses to Consider the Constitutionality of the Equitable Mootness Doctrine

The doctrine of equitable mootness is in the news again.  The Supreme Court recently denied a cert. petition in a case where the petitioner wanted the doctrine ruled unconstitutional. KK-PB Financial LLC v. 160 Royal Palm...more

Equitable Mootness Applied Again: The Fifth Circuit Refuses to Hear an Appeal

The Fifth Circuit recently dismissed an appeal of a confirmation order as equitably moot. The decision was based on three key factors: the appellant hadn’t obtained a stay pending appeal, the plan had been substantially...more

Bankruptcy Court Won’t Dabble in Case Concerning a Marijuana Business

“[E]nsnared between his involvement in a business that is legal under the laws of Arizona but illegal under federal law,” one debtor’s chapter 13 petition was recently dismissed due to his undisputed violations of the...more

Creditors Barred from Asserting $53 Million Claim: A Look at the Excusable Neglect Standard

Another case shows the perils of waiting until the final minutes to meet a court deadline. In re U-Haul, 21-bk-20140, 2021 Bankr LEXIS 3373 (Bankr. S.D. W. Va. Dec. 10, 2021). The debtor is a well-known truck rental...more

Recent Decision on Derivative Standing by a Creditors’ Committee to Challenge a Lender’s Liens

In many chapter 11 cases, creditors’ committees can play a vital role in maximizing the recoveries of unsecured creditors. But the powers of creditors’ committees are circumscribed by both the Bankruptcy Code and case law....more

Unqualified "Cares" Act Funds Can't Be Used To Pay Creditors

U.S. Bankruptcy Judge Craig A. Gargotta rejected a debtor’s attempt to use “CARES Act” funds, which it did not actually qualify for, to pay creditors in its chapter 11 case. BR Healthcare Solutions (the “Debtor”)...more

Executory Contracts: Third Circuit Does Not Recognize the Doctrine of Implied Assumption

A recent case before bankruptcy judge Karen B. Owens of the United States Bankruptcy Court for the District of Delaware, In re Dura Auto. Sys., LLC, No. 19-12378 (KBO), 2021 WL 2456944 (Bankr. D. Del. June 16, 2021), provides...more

Preference Avoidance Actions: When Late is Ordinary

A recent case shows how even late payments can be used to satisfy the ordinary course of business defense in a preference avoidance action.  Baumgart v. Savani Props Ltd. (In re Murphy), Case No. 20-11873, Adv. Pro. No....more

Court Dismisses Bankruptcy Case to Enable Debtor to Seek a Paycheck Protection Loan

It is well known in the restructuring world that a debtor in bankruptcy can’t get a PPP loan. But what if you’re a debtor and decide a PPP loan could save your business? Will a court dismiss the case so you can seek a loan?...more

Section 1126 of the Bankruptcy Code and the Dangers of Sleeping on Your Rights as a Creditor

A seat at the table: this is what you likely want when your financial interests are drawn into a bankruptcy court proceeding. You’ll seek to be heard and do what you can to maximize your recovery. This is especially true if...more

Delaware Bankruptcy Court Teaches Important Lesson on Timely Lien Perfection

Perfect your liens on time or you may lose them. That’s the painful lesson U.S. Bankruptcy Judge Karen B. Owens taught Halliburton Energy Services, Inc. in her recent decision. Ruling on plaintiff-debtor Southland Royalty...more

Federal Appeals Court Addresses Equitable Mootness Doctrine

Courts reviewing a bankruptcy court’s decision to approve a chapter 11 reorganization plan over the objections of an interested party must consider not only the merits, but also (if implementation of the plan was not stayed)...more

Third Circuit Addresses the Due Process Rights of Asbestos Claimants

When there are large numbers of substantial individual tort claims against a debtor, potentially involving claimants unknowable to the debtor who themselves may not know they have a claim, the bankruptcy process faces special...more

Federal Appeals Court Rules on Requirements for Involuntary Bankruptcy

Section 303 of the Bankruptcy Code allows creditors to initiate an involuntary bankruptcy case against a debtor. The petition initiating the case must be filed by creditors holding claims aggregating to at least $10,000, and...more

Bankruptcy Court Addresses Standard For Recovery Of An Alleged Fraudulent Transfer From A Subsequent Transferee

The Bankruptcy Code gives a trustee powers to avoid certain pre-bankruptcy transfers of the debtor’s property to other entities. For example, a trustee can avoid transfers made with the intent to impair the ability of...more

A Bankruptcy Code Chapter 15 Primer: Decision in New York Addresses Key Issues of Jurisdiction, Recognition, Public Policy, and...

Judge Martin Glenn last week issued a decision in two related chapter 15 cases, In re Foreign Econ. Indus. Bank Ltd. “Vneshprombank” Ltd., No. 16-13534, and In re Larisa Markus, No. 19-10096, 2019 Bankr. LEXIS 3203 (Bankr....more

District Court Rules on Property of the Debtor Requirement for Fraudulent Transfer Claims

Section 548 of the Bankruptcy Code enables trustees to avoid certain pre-bankruptcy transfers of “an interest of the debtor in property,” where the transfer was intended to defraud creditors or where the transfer was made...more

Wagoner Rule, Episode 2: An Outsider Serving a Managerial Role Is an Insider

We previously discussed Bankruptcy Judge Martin Glenn’s analysis of the Wagoner Rule in the Feltman v. Kossoff & Kossoff LLP (In re TS Empl., Inc.) case. The bankruptcy trustee (the “Trustee”) had asserted a fraud claim...more

Delaware Court Grants Substantial Contribution Award to Mechanic’s Lien Creditors

Delaware Bankruptcy Judge Brendan Shannon granted mechanic’s lien claimants $1.6 million for making a substantial contribution in a case by “demonstrably and materially facilitating the process of reorganization.” In re M & G...more

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