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Tenth Circuit BAP Holds that Section 541 of the Bankruptcy Code Doesn’t Invalidate Transfer Restrictions in LLC Operating...

In a recent decision by the Tenth Circuit Bankruptcy Appellate Panel, the court held that a chapter 7 trustee could not sell an LLC membership interest pursuant to section 363 of the Bankruptcy Code because of a transfer...more

Bankruptcy Court Narrowly Construes Section 546(e) Safe Harbor

On August 18, 2022, the United States Bankruptcy Court for the Southern District of Indiana, in In re BWGS, LLC, No. 19-01487-JMC-7A, 2022 WL 3568045 (Bankr. S.D. Ind. Aug. 18, 2022), narrowly interpreted the safe harbor...more

Post Siegel Ruling: Tenth Circuit Orders Refunds for Overpayment of U.S. Trustee Fees

On June 6, 2022, the Supreme Court issued a unanimously ruling in Siegel v. Fitzgerald, 142 S. Ct. 1770 (U.S. June 6, 2022) that the increase in fees payable to the U.S. Trustee system in 2018 violated the uniformity aspect...more

11th Circuit Approves of Third-Party Releases Despite Debtor’s Failure to Comply with Strict Notice Requirements of Bankruptcy...

Overview - Although a discharge might not release third parties and protects only the debtor against a determination of personal liability, in In re Le Ctr. on Fourth, LLC, 17 F.4th 1326 (11th Cir. 2021), the Eleventh...more

Revisiting the Supreme Court’s 2020 Decision in Acevedo Barring Entry of Nunc Pro Tunc Orders: How to Ensure Your Employment and...

In 2020, the United States Supreme Court issued a decision in Archdiocese of San Juan v. Acevedo Feliciano, 140 S. Ct. 696 (2020) strictly limiting the ability of federal courts to enter orders nunc pro tunc[GF1]....more

Eleventh Circuit Announces Differing Standards for Approval of Third Party Releases

The Eleventh Circuit Court of Appeals recently issued an opinion in In re Centro Group, LLC, No. 21-11364, 2021 WL 5158001 (11th Cir. Nov. 5, 2021), in which it clarified the two separate and distinct standards for approving...more

U.S. Supreme Court Seems Poised to Address Constitutionality of 2018 U.S. Trustee Fee Increase

Back in July, Craig Eller wrote in The Bankruptcy Protector about the continuing confusion amongst courts and litigants regarding the applicability of a 2018 increase in fees payable to the Office of the United States Trustee...more

10/12/2021  /  Chapter 11 , Debtors , Fees , Trustees

Consensus Builds That Some Private Student Loans Can Be Discharged in Bankruptcy

Last month, the United States Court of Appeals for the Second Circuit, in Homaidan v. Sallie Mae, Inc., 3 F.4th 595 (2d Cir. 2021), affirmed a New York federal court's ruling that private student loans are not explicitly...more

8/11/2021  /  Borrowers , Chapter 7 , Debt , Student Loans

Supreme Court: Merely Holding Property Isn’t a Violation of the Automatic Stay

In City of Chicago, Illinois v. Fulton, No. 19-357, 2021 WL 125106, at *1 (U.S. Jan. 14, 2021), the United States Supreme Court considered the issue of whether the mere retention of estate property after the filing of a...more

Employing Narrow Reading of Section 506(d), Ninth Circuit Holds That the Basis for Disallowance of a Claim Must be Considered...

In Lane v. Bank of New York Mellon (In re Lane), No. 18-60059, 2020 WL 2832270 (9th Cir. June 1, 2020), the United States Court of Appeals for the Ninth Circuit was asked to decide whether a bankruptcy court may void a lien...more

6/9/2020  /  Bankruptcy Court , Liens

CARES Act Makes Small Business Bankruptcy More Accessible

Companies with Debt Up to $7,500,000 Now Eligible for Relief - The primary purpose of the new CARES Act is to provide emergency financial and health care assistance to individuals, families, and businesses that are...more

[Webinar] Navigating the Legal, Economic, and Business Challenges of the Coronavirus Pandemic - March 26th, 1:15 pm - 3:00 pm EDT

Nelson Mullins will host a webinar on topics related to the COVID-19 outbreak on March 26. Topics to be presented: - Business Continuity, Force Majeure, and Potential Defenses to COVID-19 Related Contractual...more

Third Circuit Hands Down Important Decision Providing Guidance on Liquidation of Repo ‘Credit Enhancements’

The United States Court of Appeals for the Third Circuit issued an opinion on December 24, 2019, In re Homebanc Mortgage Crop., No. 18-2887, 2019 WL 7161215(3rd Cir. De. 24, 2019) that has significant consequences for...more

When is a “Mere Conduit” More Than A “Mere Conduit”? The Second Circuit Has a Clue

Section 546(e) of the Bankruptcy Code is a safe harbor provision that establishes that a trustee or debtor-in-possession may not avoid a transfer “by or to... a financial institution.. in connection with a securities...more

No Dice: State Law Precludes Recovery of $50,000,000 Gaming License Fee

In 2007, Philadelphia Entertainment and Development Partners, LP dba Foxwoods Casino Philadelphia (“Plaintiff”) secured a gaming license from Pennsylvania for $50,000,000 with the understanding that it open its casino...more

Applying Jevic (Part 3): How Courts Are Interpreting and Applying the Supreme Court’s Ruling on Structured Dismissals and Priority...

The Bankruptcy Protector has previously provided a succinct summary of all cases decided post-Jevic. In this update, we discuss the cases decided between May 10, 2019 and November 27, 2019....more

The Sixth Circuit Sets Standard on Power Struggle at Play in Bankruptcy Proceedings Between a Federal Agency and its Federally...

In In re FirstEnergy Solutions Corp., 2019 WL 6767004 (6th Cir. Ct. App.), the United States Court of Appeals affirmed in part, reversed in part, and remanded to the bankruptcy court for further consideration, the...more

First Circuit: Only the Trustee may Pursue Causes of Action Against Ponzi Scheme Net Winners

The First Circuit Court of Appeals issued an opinion on October 29, 2019, in In re TelexFree, LLC, No. 18-2001, 2019 WL 5558088, at *1 (1st Cir. Oct. 29, 2019) that has significant consequences for ponzi scheme litigation in...more

At Odds with the First Circuit, the Seventh Circuit Adopts a Questionable Standard for Determining the Sufficiency of Financing...

In In re I80 Equip., LLC, 938 F.3d 866, 874 (7th Cir. 2019), the Seventh Circuit held that a financing statement under the Uniform Commercial Code sufficiently describes collateral by referring to an unattached security...more

Motorists Catch Break in Decades Long Fight Following First Circuit’s Holding on Request for Relief from Automatic Stay

In In re Financial Oversight and Management Board for Puerto Rico, 2019 WL 4667518 (1st Cir. 2019), the United States Court of Appeals affirmed in part and vacated in part the Article III court’s partial denial of Plaintiffs’...more

Ninth Circuit: No Consolidation Absent Notice to Creditors of Non-Debtors

In In re Mihranian, 2019 WL 4252115 (9th Cir. 2019), the Ninth Circuit Court of Appeals held, as a matter of first impression, that a party moving for substantive consolidation of the debtor's bankruptcy estate with the...more

Buyer Beware: Anti-Assignment Clause in Promissory Note Bars Claim Purchaser from Collecting in Bankruptcy

In In re Woodbridge Grp. of Companies, LLC, No. BR 17-12560-BLS, 2019 WL 4305444 (D. Del. Sept. 11, 2019), the United States District Court for the District of Delaware affirmed an opinion by Bankruptcy Judge Kevin Carey, and...more

Data Privacy and Bankruptcy—Notable Bankruptcy Code Provisions and Bankruptcy Rules

The Bankruptcy Protector recently discussed notable non-bankruptcy provisions that must be consulted to ensure compliance with privacy issues. In this post, we discuss notable Bankruptcy Code provisions and Bankruptcy Rules...more

Court Holds that Trustee May Recover Proceeds from Fraudulently Transferred Property

There is currently a split in authority on the issue of whether a trustee may recover from an immediate or mediate transferee if the recipient received proceeds from a fraudulent transfer but not the fraudulently transferred...more

Data Privacy and Bankruptcy—Notable Non-bankruptcy Privacy Laws

Privacy issues implicate several Bankruptcy Code sections and Bankruptcy Rules.  The debtor must also comply with non-bankruptcy rules concerning privacy to the extent that such rules are not inconsistent with the Bankruptcy...more

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