News & Analysis as of

Commercial Bankruptcy Appeals Chapter 7

Rosenberg Martin Greenberg LLP

Timing May Be Everything When Employing Bankruptcy Professionals

When Byron David filed a Chapter 7 bankruptcy case in July of 2018, Donald King was appointed Chapter 7 trustee. King filed an application to retain a law firm as his counsel. The bankruptcy court granted that application....more

King & Spalding

The Seventh Circuit Upholds District Court’s Decision That Safe Harbor Provision of Section 546(e) Applies to Privately Held...

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A recent ruling from the United States Court of Appeals for the Seventh Circuit provides additional comfort for lenders receiving full repayment in connection with leveraged acquisitions. The U.S. Bankruptcy Code gives...more

Patterson Belknap Webb & Tyler LLP

Tenth Circuit Holds that Sovereign Immunity Does Not Limit Section 544 Claim

Section 544(b)(1) of the Bankruptcy Code enables a trustee to step into the shoes of a creditor and avoid a transfer “of an interest of the debtor in property” that an unsecured creditor could avoid under applicable state...more

Jenner & Block

April 2023 - Recent Developments in Bankruptcy Law

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AUTOMATIC STAY - 1.1 Covered Activities 1.1.a Court denies injunction against actions involving debtors’ affiliates. Shortly after filing their chapter 11 cases, the debtors in possession sought, in the alternative,...more

Jones Day

New Appellate Court Ruling on Priority of Straddle-Year Taxes in Bankruptcy

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A basic tenet of bankruptcy law, premised on the legal separateness of a debtor prior to filing for bankruptcy and the estate created upon a bankruptcy filing, is that prepetition debts are generally treated differently than...more

Kramer Levin Naftalis & Frankel LLP

Third Circuit Opinion Clarifies Creditors Can Pursue Claims Abandoned by Bankruptcy Trustees

The Third Circuit, in Artesanias Hacienda Real S.A. de C.V. v. N. Mill Capital, LLC (In re Wilton Armetale, Inc.), 968 F.3d 273 (3d Cir. 2020), issued a decision with potential implications for creditors who wish to pursue...more

Troutman Pepper

A Win for Lenders: Seventh Circuit Finds UCC-1 Collateral Description Reference Sufficient

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In a win for lenders, on September 11, the U.S. Court of Appeals for the Seventh Circuit reversed the U.S. Bankruptcy Court for the Central District of Illinois, holding that the collateral description in the UCC-1 financing...more

FordHarrison

Non-Compete News: – Georgia Court Interprets Non-Compete Statute's "Sale-of-a-Business" Provision

FordHarrison on

Georgia’s Restrictive Covenants Act (O.C.G.A. § 13-8-50 et seq.) (“RCA”) governs Georgia non-compete agreements entered into after May 2011. Very few courts have interpreted the RCA since its inception. In Bearoff v. Craton,...more

Patterson Belknap Webb & Tyler LLP

Another Ruling on Public Auctions Versus Private Sales Under Section 363

Two weeks ago, we discussed asset sales under Bankruptcy Code section 363. As that post noted, section 363 requires court approval for asset sales outside the ordinary course of business, with courts ensuring that sales...more

Bradley Arant Boult Cummings LLP

Take It to the Limit: Increase in Chapter 13 Debt Limits

Individuals have several options when filing bankruptcy. Chapter 13 is often preferred for individuals with regular income who wish to keep their homes and other secured assets. In a Chapter 13 filing, the court will approve...more

Patterson Belknap Webb & Tyler LLP

Another Gotcha for the Calendar: Section 365(d)(1)

Although it may be difficult to define precisely what an “executory contract” is (with the Bankruptcy Code providing no definition), I think most bankruptcy lawyers feel how the late Supreme Court Justice Potter Stewart...more

Kramer Levin Naftalis & Frankel LLP

Fifth Circuit Holds Executory Contract Not Listed on Bankruptcy Schedules Is Automatically Rejected Upon Expiration of 60-Day...

The Bottom Line - The Fifth Circuit recently held in RPD Holdings, L.L.C. v. Tech Pharmacy Services (In re Provider Meds, L.L.C.), No. 17-1113 (5th Cir. Oct. 29, 2018), that a patent license that was not specifically...more

Jones Day

From the Top in Brief: U.S. Supreme Court Clarifies Whether Debts Based on False Statements Can Be Discharged in Bankruptcy

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On June 4, 2018, the U.S. Supreme Court ruled in Lamar, Archer & Cofrin, LLP v. Appling, No. 16-1215, 138 S. Ct. 1752, 2018 WL 2465174 (U.S. June 4, 2018), that an individual debtor's false statement about a single asset, as...more

McGuireWoods LLP

Statement By Debtor About Single Asset Can Be Statement Respecting Debtor’s Financial Condition Under Bankruptcy Code Section...

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Section 523(a)(2)(B) of the Bankruptcy Code provides that a discharge under the Bankruptcy Code does not discharge an individual debtor from any debt for money, property, services, or an extension, renewal, or refinancing of...more

Ward and Smith, P.A.

In Chapter 7, Oral Lies Are Safer Than Written Lies

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In my last article, I discussed how the Fourth Circuit Court of Appeals affirmed the denial of a Chapter 7 debtor’s discharge because the debtor intentionally lowballed the value of his interest in a real estate investment...more

BakerHostetler

Supreme Court Holds That a Statement About a Single Asset Can Be a Statement Respecting a Debtor's Financial Condition

BakerHostetler on

The Supreme Court held that a statement about a single asset can be a “statement respecting the debtor’s financial condition” for purposes of determining the application of the exception to discharge set forth in Section...more

BCLP

SCOTUS Reminds Us To Get It In Writing When Dealing with Someone that Owes You Money

BCLP on

The recent decision from the United States Supreme Court in Lamar, Archer & Cofrin, LLP v. Appling (“Lamar”), further restricts a creditor’s ability to pursue future recovery on its debt through a nondischargeability action...more

Patterson Belknap Webb & Tyler LLP

Supreme Court Resolves Circuit Split on the Dischargeability of Debts Obtained by Oral Misrepresentations

On June 4, the Supreme Court decided Lamar, Archer & Cofrin, LLP v. Appling, No. 16-1215, in a unanimous opinion by Justice Sotomayor. The Court affirmed the Eleventh Circuit and resolved a circuit split about the meaning of...more

Fox Rothschild LLP

U.S. Supreme Court Finds Debt Obtained By False Promises To Pay, Dischargeable

Fox Rothschild LLP on

The U.S. Supreme Court resolved a dispute about whether debts obtained by false promises to pay (or fraud) can be discharged in bankruptcy. On June 4, 2018, the U.S. Supreme Court issued an opinion affirming the U.S. Court...more

Jackson Walker

Lamar Opinion Reminds Creditors to Get in Writing Any Representations About Debtors’ Financial Conditions

Jackson Walker on

On June 4, 2018, the Supreme Court of the United States issued its opinion authored by Justice Sotomayor in Lamar, Archer & Cofrin, LLP v. Appling impacting the discharge of debts under Bankruptcy Code § 523(a)(2)(A)....more

Faegre Drinker Biddle & Reath LLP

Supreme Court Decides Lamar, Archer & Cofrin, LLP v. Appling

On June 4, 2018, the Supreme Court of the United States decided Lamar, Archer & Cofrin, LLP v. Appling, No. 16-1215, holding that a statement about a single asset can be a “statement respecting the debtor’s financial...more

Foster Garvey PC

Maritime Liens and the Automatic Stay: Impact of the Ninth Circuit’s Barnes Decision

Foster Garvey PC on

Can a Bankruptcy Court order the sale of a vessel “free and clear” of a seaman’s maritime lien for maintenance and cure under Bankruptcy Code § 363? According to the Ninth Circuit’s recent ruling in Barnes v. Sea Hawaii...more

Patterson Belknap Webb & Tyler LLP

Delaware District Court Dismisses Appeal by Creditors’ Committee After Case is Converted from Chapter 11 to Chapter 7

The Bankruptcy Code provides for the appointment of a creditors’ committee in chapter 11 bankruptcy cases. See 11 U.S.C. § 1102. There is no parallel provision applicable to chapter 7 cases. When a bankruptcy case is...more

Patterson Belknap Webb & Tyler LLP

Bankruptcy Remoteness Going to a Court of Appeals

Back in the day--say, the last two decades of the twentieth century--we bankruptcy lawyers took it largely on faith that the right structural and contractual provisions purporting to confer bankruptcy-remoteness were...more

Ward and Smith, P.A.

Limiting Ponzi Scheme Recoveries in Bankruptcy: United States Supreme Court Declines to Review Fraudulent Transfer Ruling in Favor...

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The United States Supreme Court recently declined to review a decision from the United States Court of Appeals for the Fourth Circuit favorable to a bank regarding alleged fraudulent transfers to the bank. In doing so, the...more

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