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Bankruptcy Court Liens

Patterson Belknap Webb & Tyler LLP

New Jersey Bankruptcy Court Rules That Debtor Could Not Sell its Future Accounts Receivable Prepetition

A bankruptcy court in New Jersey recently granted a debtor’s motion to dismiss the counterclaims of two creditors who purchased a percentage of the debtor’s future receivables prepetition. The court rejected the creditors’...more

Offit Kurman

Fifth Circuit Confirms Third-Party Liens Survive Chapter 11 Discharge

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The Fifth Circuit has confirmed the old adage that liens “ride through” bankruptcy regardless of a discharge. Reversing a Texas bankruptcy court, the Circuit Court has held that a statutory privilege (a lien) against property...more

Lathrop GPM

Utah Bankruptcy Court Applies “Freeze Rule” to Preserve Secured Creditor’s Lien Priority When Financing Statement Lapses...

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Pursuant to Uniform Commercial Code (UCC) § 9-515(c), a UCC-1 financing statement filed to perfect a secured party’s lien on personal property collateral lapses five years from the filing date unless the secured creditor...more

Jones Day

New York Bankruptcy Court Adopts "Realistic Possibility" Standard for Free and Clear Sales Under 11 U.S.C § 363(f)(5)

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Section 363(f)(5) of the Bankruptcy Code allows a bankruptcy trustee to sell estate property free and clear of any competing interest in the property (such as a lien or other security interest) if the interest holder "could...more

Jones Day

Secured Lenders Win Victory in Sanchez Bankruptcy

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The Ad Hoc Group of Senior Secured Noteholders and DIP Lenders (the "Ad Hoc Group") obtained a unanimous judgment in their favor in an appeal following Sanchez Energy Company's long-running, hard-fought bankruptcy case. Once...more

Cadwalader, Wickersham & Taft LLP

I’m Still Standing – Yeah, Yeah, Yeah: Wilmington Savings Fund Society v. Tamisi

In Wilmington Savings Fund Society v. Tamisi, the U.S. District Court for the Eastern District of New York upheld a bankruptcy court’s ruling that Wilmington lacked the necessary standing to enforce a mortgage lien, thereby...more

Offit Kurman

Acquisition Strategies: Navigating Section 363 Sales and the Impact of Undersecured Liens

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Section 363 of the Bankruptcy Code allows a Chapter 11 debtor to sell assets "free and clear" of existing claims, liens, encumbrances, and other liabilities. This provision facilitates expedited sales that might otherwise be...more

Troutman Pepper Locke

Navigating Jurisdictional Pitfalls: Lessons From Global One Media, Inc. v. Newtek Small Business Finance, LLC on Lien Filing...

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The Ninth Circuit Bankruptcy Appellate panel recently reaffirmed the longstanding principle that a UCC-1 financing statement securing personal property must be filed at the debtor’s location. In a recent case, the lender did...more

Loeb & Loeb LLP

SDNY Bankruptcy Court Explains Differences Between Preferential Judicial Liens v. Statutory Liens

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In Firstbase.io, Inc. v. Harbor Business Compliance Corporation, No. 24-04043, 2025 Bankr. LEXIS 1092 (Bankr. S.D.N.Y.), the U.S. Bankruptcy Court for the Southern District of New York found that a judgment execution lien...more

Eversheds Sutherland (US) LLP

In re Urban Commons 2 West LLC (Bankr. SDNY Mar. 4, 2025)

Bankruptcy Court Elects to Follow Majority Interpretation of 11 U.S.C. § 363(f)(5) On March 4, 2025, the United States Bankruptcy Court for the Southern District of New York (the Bankruptcy Court) issued a significant...more

Hudson Cook, LLP

Vehicle Titles in the Age of the Internet

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Unlike most items of personal property, a motor vehicle usually has a certificate of title. We all know that the point of a vehicle title is to show who owns the vehicle and who (if anyone) has a lien on it....more

Ropes & Gray LLP

Law Reviews, Dictionaries, and Uptiers: The Fifth Circuit Weighs In on Serta

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Market participants might be wary of opinions that begin with a recitation of academic literature and then turn to dictionaries. The former tend to be authored with an eye toward systemic change rather than direct experience...more

Proskauer Rose LLP

The End of Non-Pro Rata Uptiers? Fifth Circuit Rules that Serta Exchange was Not an “Open Market Purchase”

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The United States Court of Appeals for the Fifth Circuit (the “Fifth Circuit”) ruled on December 31, 2024 that Serta Simmons Bedding’s (“SSB”) 2020 uptier exchange included a transaction that, contrary to the assertions of...more

King & Spalding

Texas Bankruptcy Court Awards Majority Stake in Reorganized Debtor to Unsecured Creditors After Avoiding the Value of the...

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On August 3, 2023, the U.S. Bankruptcy Court for the Southern District of Texas found that the majority of the shares of stock of a reorganized debtor should be allocated to unsecured creditors, and not the secured creditors,...more

Warner Norcross + Judd

M&A Strategy Update: Union Contracts and Section 363 Sales

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In the right situations, the United States Bankruptcy Code provides powerful tools for acquiring distressed companies and realizing economic value, including synergies from vertically integrating suppliers or customers, or...more

Blank Rome LLP

Security Interests and Liens Priorities

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This practice note discusses the requirements for the attachment and perfection of consensual security interests in personal property under Article 9 of the Uniform Commercial Code (UCC). A security interest is said to attach...more

Nelson Mullins Riley & Scarborough LLP

A Rose by Any Other Name Might Get Your Lien Stripped Under Florida Law

To the long list of things people love about lawyers we can add last week’s holding by the Eleventh Circuit Court of Appeals that “Blvd.” is utterly unrecognizable as “Boulevard” – at least by Article 9 of the Uniform...more

Goodwin

TPC Bankruptcy and District Court Opinions Uphold Uptiering Transaction and Teach an Important Lesson on the Need for Express...

Goodwin on

A recent U.S. District Court for the District of Delaware opinion, In re TPC Grp. Inc., provided another instance of an uptiering transaction withstanding legal scrutiny and provides further support for the view that courts...more

Troutman Pepper Locke

Bankruptcy Court Holds Title Holder Consent Is Enough to Give Collateral Rights to Debtor to Grant Liens

Troutman Pepper Locke on

On April 28, the U.S. Bankruptcy Court for the N.D. of Oklahoma in Kirtley v. Mabrey Bank (In re Rudick) held that an entity other than the debtor may grant a lien on the debtor’s property, affirming the legal standard that...more

Nelson Mullins Riley & Scarborough LLP

Creditor Not Entitled to Post-Sale Discovery to Attempt to Amend Sale Proceeds Distribution

In In re Squirrels Rsch. Labs, LLC, No. 21-61491, 2022 WL 1310173, at *1 (Bankr. N.D. Ohio Apr. 29, 2022), the United States Bankruptcy Court for the Northern District of Ohio recently addressed whether post-sale of the...more

King & Spalding

Bankruptcy Court Enters Verdict Against Lender Found to Have Caused Borrower’s Demise

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On December 23, 2021, Judge Stacey Jernigan of the U.S. Bankruptcy Court for the Northern District of Texas issued a verdict, following a bench trial, in favor of the Chapter 7 trustee of a metal manufacturing business and...more

Smith Debnam Narron Drake Saintsing & Myers,...

2017 Amendments to Bankruptcy Rules Do Not Permit Lien Avoidance Through Chapter 13 Plan

The U.S. Bankruptcy Court for the Eastern District of North Carolina recently rejected a debtor’s argument that the 2017 Amendments to Rules 3012 and 3015 of the Federal Rules of Bankruptcy Procedure permitted her to avoid a...more

Patterson Belknap Webb & Tyler LLP

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

Patterson Belknap Webb & Tyler LLP

New Court Ruling on Whether Avoidance Powers Require Benefit to Creditors

The Bankruptcy Code grants the power to avoid certain transactions to a bankruptcy trustee or debtor-in-possession. See, e.g., 11 U.S.C. §§ 544, 547–48. Is there a general requirement that these avoidance powers only be...more

Emmet, Marvin & Martin LLP

Pre-judgment Attachment Lien May Be Sufficient “cause” To Lift Automatic Stay

11 U.S.C. 362(d)(1) empowers the Bankruptcy Court to grant relief from the automatic stay on the request of a party-in-interest “for cause, including lack of adequate protection of an interest in property of such party in...more

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