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Cramdown Bankruptcy Code Bankruptcy Court

Mayer Brown

Adler: Court of Appeal sets aside sanction of a Restructuring Plan

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In the first appeal of a restructuring plan under Part 26A Companies Act 2006, the English Court of Appeal unanimously set aside the first instance decision sanctioning the plan proposed by AGPS BondCo PLC, part of the Adler...more

Jones Day

Business Restructuring Review | March–April 2022

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MODIFICATION OF SECURED LOAN UNDER CRAMDOWN CHAPTER 11 PLAN WARRANTED DUE TO PLAN FEASIBILITY THREAT - Many recent court rulings concerning the treatment of secured creditors under a chapter 11 plan have focused on...more

Jones Day

Confirmation Denied: Chapter 11 Plan Did Not Satisfy New Value Exception to Absolute Priority Rule Without Market Testing

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When existing interest holders attempt to retain ownership of a chapter 11 debtor after confirmation of a nonconsensual plan of reorganization, the Bankruptcy Code's plan confirmation requirements, including well-established...more

Fox Rothschild LLP

A New Standard For Chapter 11 Cramdown Plans – The Third Circuit Court Of Appeal’s Refusal To Strictly Enforce Subordination...

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The Bankruptcy Code provides that subordination agreements are enforceable in bankruptcy to the same extent that such agreements are enforceable under non-bankruptcy law. 11 U.S.C. § 510(a). However, Section 1129(b)(1) of...more

Patterson Belknap Webb & Tyler LLP

Rough Justice: Third Circuit Issues Important Decision on Unfair Discrimination

“Unfair discrimination is rough justice. It exemplifies the Code’s tendency to replace stringent requirements with more flexible tests that increase the likelihood that a plan can be negotiated and confirmed,” announced Judge...more

Ward and Smith, P.A.

Fourth Circuit Provides Relief to Chapter 13 Debtors for Some Underwater Mortgages

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In a victory for Chapter 13 debtors, the United States Court of Appeals for the Fourth Circuit recently issued a major decision that changes the way bankruptcy courts in North Carolina will deal with certain home mortgages in...more

Jones Day

Due-on-Sale Clause Not Mandatory in Cramdown Chapter 11 Plan, and Plan Acceptance Requirement Applies on "Per Plan" Basis

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In Grasslawn Lodging, LLC v. Transwest Resort Properties Inc. (In re Transwest Resort Properties, Inc.), 881 F.3d 724 (9th Cir. 2018), the U.S. Court of Appeals for the Ninth Circuit considered, in connection with a...more

Mintz - Bankruptcy & Restructuring Viewpoints

Ninth Circuit: No Ulterior Motive, No Bad Faith When Buying Claims to Block Confirmation

A recent Ninth Circuit Court of Appeals decision provides insight into “bad faith” claims-buying activity; specifically whether a creditor’s purchase of claims for the express purpose of blocking plan confirmation is...more

Mintz - Bankruptcy & Restructuring Viewpoints

Supreme Court Bankruptcy Thoughts: Scope of Safe Harbor and Appellate Review

The Supreme Court recently addressed two bankruptcy issues. In its Merit Management opinion, the Court resolved a circuit split regarding the breadth of the safe harbor provision which protects certain transfers by financial...more

Skadden, Arps, Slate, Meagher & Flom LLP

Supreme Court Clarifies Standard of Appellate Review of Creditor’s Insider Status

In U.S. Bank N.A. v. Village at Lakeridge, LLC, the U.S. Supreme Court issued an important decision on standards of appellate review, holding that appellate courts should review a bankruptcy court’s determination of whether a...more

Patterson Belknap Webb & Tyler LLP

In “Non-Statutory Insider” Case, Supreme Court Clarifies the Standard of Review for Mixed Questions of Law and Fact

In U.S. Bank Nat'l Ass'n v. Village at Lakeridge, LLC, No. 15-1509, 2018 U.S. LEXIS 1520 (Mar. 5, 2018), the Supreme Court analyzed the appropriate standard of review for appellate courts reviewing a bankruptcy court’s...more

Jones Day

Supreme Court Adopts Deferential Standard of Review on Chapter 11 Insider Status

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In U.S. Capital Bank N.A. v. Village at Lakeridge, LLC, No. 15-1509 (U.S. Mar. 5, 2018), the U.S. Supreme Court held that an appellate court should apply a deferential standard of review to a bankruptcy court's decision as to...more

Alston & Bird

U.S. Supreme Court Bolsters Clear Error Standard for Mixed Questions of Fact and Law

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Our Bankruptcy & Financial Restructuring Group analyzes the U.S. Supreme Court’s decision on which kind of court is best suited to solve a mixed question. - Non-statutory status - The case at hand - Applying the clear...more

Sullivan & Worcester

Lenders Beware: The 9th Circuit Dilutes Voting Power in Multi-Debtor Cases (In re Transwest Resort Properties Inc.)

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Courts are often faced with the situation in which affiliated debtors file for Chapter 11 reorganization and request to have their cases jointly administered. While joint administration does not, without more, cause...more

Kramer Levin Naftalis & Frankel LLP

Supreme Court Lakeridge Decision Clarifies the Standard of Review of Mixed Questions of Law and Fact

In another decision affecting Chapter 11 cases, U.S. Bank National Association v. Village at Lakeridge, --- S. Ct. ---, 2018 WL 1143822 (2018), on March 5, 2018, the United States Supreme Court issued a unanimous decision,...more

Nelson Mullins Riley & Scarborough LLP

Who Is A Non-Statutory Insider? The U.S. Supreme Court Provides (Some) Guidance on the Appropriate Standard of Review for this...

On March 5, 2018 the United State Supreme Court issued its unanimous decision in U.S. Bank NA v. The Village at Lakeridge, LLC, 583 U.S. ___ (2018), answering the narrow question of what is the proper standard of review for...more

Faegre Drinker Biddle & Reath LLP

Supreme Court Decides U.S. Bank, N.A. v. Village at Lakeridge, LLC

On March 5, 2018, the Supreme Court of the United States decided U.S. Bank, N.A. v. Village at Lakeridge, LLC, No 15-1509, holding that a bankruptcy court’s determination of whether a set of facts demonstrated an arms-length...more

Patterson Belknap Webb & Tyler LLP

One and Done. Cramdown Requirement for an Impaired Assenting Class Applies on a Per-Plan, Not a Per-Debtor, Basis.

Confirmation of a Chapter 11 plan of reorganization generally requires the consent of each impaired class of creditors. But, upon satisfaction of additional statutory requirements, a plan proponent can obtain confirmation of...more

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