News & Analysis as of

Article III Creditors Standing

Jones Day

U.S. Supreme Court Bankruptcy Update

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The U.S. Supreme Court handed down three bankruptcy rulings to finish the Term ended in July 2024. The decisions address the validity of nonconsensual third-party releases in chapter 11 plans, the standing of insurance...more

Hudson Cook, LLP

Technical Violations of State Collection Practices Laws Can Lead to Class Action Liability

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If you are reading this article, you are likely aware that a creditor collecting its own debts in its own name is not a "debt collector" under the federal Fair Debt Collection Practices Act ("FDCPA") or its implementing rule,...more

Troutman Pepper

Third Circuit Holds “Confusion, Without More” Is Not Enough to Confer Standing Under the FDCPA

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The U.S. Court of Appeals for the Third Circuit has recently underscored the fact that a plaintiff does not automatically gain Article III standing under the Fair Debt Collections Practices Act (FDCPA) simply because they are...more

Jones Day

Second Circuit: Bankruptcy Courts Have Inherent Authority to Impose Civil Contempt Sanctions

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Because bankruptcy courts were created by Congress rather than under Article III of the U.S. Constitution, there is a disagreement over whether bankruptcy courts, like other federal courts, have "inherent authority" to impose...more

Jones Day

Ninth Circuit: Standard for Constitutional Standing Applies to Bankruptcy Appeals

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Federal appellate courts have traditionally applied a "person aggrieved" standard to determine whether a party has standing to appeal a bankruptcy court order or judgment. However, this standard, which requires a direct,...more

Troutman Pepper

New Jersey Federal Court Dismisses FDCPA Claim Based on Alleged Failure to Obtain Proper License for Lack of Standing

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In Valentine v. Mullooly, Jeffrey, Rooney & Fylnn LLP the U.S. District Court for the District of New Jersey found that the plaintiff had not suffered an injury in fact and therefore lacked standing to assert a claim under...more

Rosenberg Martin Greenberg LLP

Is the End Near for Third Party Releases In Chapter 11 Plans?

When the Bankruptcy Reform Act of 1978, the foundation on which the current Bankruptcy Code is constructed, was enacted, bankruptcy cases customarily involved a debtor addressing claims only against it. Consistent with that...more

Jones Day

Voting Right Assignment Unenforceable, But Subordinated Creditor Lacked Standing to Participate in Chapter 11 Plan Confirmation...

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In In re Fencepost Productions Inc., 2021 WL 1259691 (Bankr. D. Kan. Mar. 31, 2021), the U.S. Bankruptcy Court for the District of Kansas recently addressed the enforceability of a provision in a pre-bankruptcy subordination...more

Kramer Levin Naftalis & Frankel LLP

Fifth Circuit Holds That Creditor Lacks Constitutional Standing to Appeal

The Fifth Circuit in Nustar Energy Services, Inc. v. M/V Cosco Auckland, Case No. 17-20246 (5th Cir. Jan. 14, 2019), recently held that a subcontractor creditor lacked constitutional standing to appeal a lower court’s ruling...more

Orrick, Herrington & Sutcliffe LLP

Plaintiffs Cannot Claim Creditor Status Retroactively

The Fifth Circuit Court of Appeals reminded the plaintiff that standing is “determined as of the commencement of the suit” and post filing claims purchases will not suffice to establish standing. ...more

Dorsey & Whitney LLP

Missed Calls Don’t Cut It: Injury in Fact is Required for Each Call and Must Be Traceable to the Use of an ATDS

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In the latest dismissal of a TCPA case for lack of Article III standing, a District Court in California held that a plaintiff does not suffer an injury in fact from calls she did not hear, calls she heard but did not answer,...more

Greenberg Glusker LLP

Mind the Statutory Gap (aka A Jurisdictional Mess)

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As we all know, on June 9 of this year, the Supreme Court issued its long awaited decision in Executive Benefits Ins. Agency vs. Arkison, 134 S. Ct. 2165, 189 L. Ed. 2d 83 (2014), which we had hoped would resolve the open...more

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