News & Analysis as of

Make-Whole Doctrine

BakerHostetler

Not So Fast: Fifth Circuit Partially Reverses the NLRB’s Thryv Decision

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In a follow-up to our December 2022 blog post and December 2023 year-end roundup alert regarding the National Labor Relations Board’s (NLRB or Board) decision in Thryv, Inc., the United States Court of Appeals for the Fifth...more

Ogletree, Deakins, Nash, Smoak & Stewart,...

Beltway Buzz - April 2023 #3

He’s Running. President Joe Biden announced this week that he will run for reelection in 2024. President Biden has stated that he is the most pro-union president in history, so the Buzz will not be surprised if labor and...more

Bodman

NLRB Expands Potential Recovery in Unfair Labor Practice Cases

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The National Labor Relation Act (“Act”) permits the National Labor Relations Board (“Board” or “NLRB”) to award damages to employees that put them in the financial position in which they would have been if no violation had...more

Polsinelli

“Outlook Not So Good” – An Employer’s Guide to the NLRB’s 2023 Agenda

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“Should Employers have any hope for impartiality and good decisions from the National Labor Relations Board (“NLRB” or the “Board”) in 2023?”  Posed to the old Magic 8 Ball, the answer is “Don’t count on it.”...more

BakerHostetler

NLRB Gifts Employees Expansive Remedies in Time for the Holiday Season

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“You get more remedies! You get more remedies! Everybody gets more remedies!” Employers found to have committed an unfair labor practice (ULP) now may be required to compensate employees for interest and late fees on...more

Venable LLP

There’s a New Remedy in Town: NLRB Adds Consequential Damages as a Remedy for Unfair Labor Practices

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On December 13, 2022, in a 3-2 decision, the National Labor Relations Board (NLRB or the Board) added consequential damages as a “make-whole” remedy for unfair labor practices, expanding the relief available to workers....more

Holland & Knight LLP

NLRB Expands Standard Remedies Available to Victims of Unfair Labor Practices

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In Thryv, Inc., 372 NLRB No. 22 (2022), the National Labor Relations Board (NLRB or Board) held that to best effectuate the purposes of the National Labor Relations Act (NLRA), the standard make-whole remedy must compensate...more

Littler

National Labor Relations Board Expands Make-Whole Remedy

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On December 13, 2022, the National Labor Relations Board (“Board”) made another move to expand relief available to workers who allege unfair labor practices by their employers. Historically, employees seeking relief under the...more

Ogletree, Deakins, Nash, Smoak & Stewart,...

NLRB Expands Make-Whole Remedy to Include ‘Direct or Foreseeable’ Damages

Fulfilling a top priority for National Labor Relations Board (NLRB) General Counsel Jennifer A. Abruzzo’s activist agenda, on December 13, 2022, the Board issued a decision that expands, arguably beyond statutory limits, the...more

Miller Canfield

NLRB Issues Twin Rulings Expanding the Scope of 'Make-Whole' Remedies and Easing Union Organizing Burdens

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​​​​​​​On December 13, 2022, the National Labor Relations Board (NLRB) expanded the remedies that may be awarded in unfair labor practice cases. The board ruled 3-2 that affected employees may recover compensation for "all...more

Miles & Stockbridge P.C.

NLRB Brings Back Micro-Units, Paving the Way for More Union Organizing

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The National Labor Relations Board on Wednesday revived an Obama-era standard that will make it easier for unions to organize employees and win elections. In a 3-2 decision in American Steel Construction Inc., the Board...more

Polsinelli

Festive NLRB Provides Holiday Gifts to Unions/Employees

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​​​​​​​December never is a “slow” month in “labor law land.” Even though offices are winding down and some are closing for the holidays, the National Labor Relations Board (the “Board”) always enjoys dropping a few seismic...more

Miles & Stockbridge P.C.

NLRB Broadens Traditional Remedy to Include ‘Direct or Foreseeable’ Damages

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The National Labor Relations Board announced Tuesday that it was expressly expanding the scope of its traditional “make whole” remedy to require employers to compensate wrongfully terminated employees for all “direct or...more

Nelson Mullins Riley & Scarborough LLP

Make-Whole Payments and Solvent Debtors: A Potentially Widening Circuit Split

The United States Court of Appeals for the Fifth Circuit entered its (second) opinion in the case of In re Ultra Petroleum Corporation, Case No. 21-20008, on October 14, 2022, potentially widening a circuit split on the issue...more

Akin Gump Strauss Hauer & Feld LLP

Make (Whole) a Minute: A Review of the Ultra Unimpairment Decision

Welcome to the first Akin Gump client alert sub-titled Make (Whole) a Minute. These alerts are designed to be short digestible updates or commentaries on topics of interest to the institutional investment community that take...more

Rivkin Radler LLP

Eleventh Circuit Affirms “Exceptional Case” Ruling: Insurer Had No Duty to Defend Construction Debris Claim Where Amended...

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Eleventh Circuit Affirms “Exceptional Case” Ruling: Insurer Had No Duty to Defend Construction Debris Claim Where Amended Complaint Omitted Crucial Fact Implicating Pollution Exclusion The Eleventh Circuit, affirming the...more

King & Spalding

PG&E Bankruptcy Court Finds that Postpetition Interest for Unsecured Creditors Must be Calculated at the Federal Judgement Rate

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In a decision entered just before the end of the year in the PG&E bankruptcy cases, Judge Montali issued an opinion (the “Opinion”) finding that unsecured creditors in a solvent bankruptcy case are entitled under the...more

Troutman Pepper Locke

Make-Whole Provision Upheld by Bankruptcy Court Despite Lender's Loan Acceleration

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In a win for lenders, on March 18, the U.S. Bankruptcy Court for the Southern District of New York held that an unambiguous make-whole provision in a loan contract was enforceable under New York law, despite the fact that the...more

Kramer Levin Naftalis & Frankel LLP

Fifth Circuit Disallows Make-Whole Payment in Bankruptcy

On Jan. 19, 2019, the U.S. Court of Appeals for the Fifth Circuit vacated a bankruptcy court decision awarding Ultra Petroleum Corp. noteholders $201 million in make-whole payments and $186 million in post-petition interest. ...more

Jones Day

Fifth Circuit Suggests Claims for Make-Whole Amounts Should Be Disallowed

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The Situation On January 17, 2019, the Fifth Circuit strongly suggested that claims for make-whole damages be characterized as "unmatured interest" and that claims for postpetition interest on unsecured debt be limited in...more

Spilman Thomas & Battle, PLLC

Recent Developments with Make-Whole Provisions in Chapter 11 Cases

A make-whole provision (also known as prepayment premium or call protection) in a loan agreement usually requires a debtor to pay a penalty based on a fixed percentage of the amount of a loan balance the debtor voluntarily...more

White and Williams LLP

Supreme Court of Kentucky Holds Plaintiff Can Recover for Stigma Damages in Addition to Repair Costs Resulting From Property...

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In Muncie v. Wiesemann, 2018 K.Y. LEXIS 257, the Supreme Court of Kentucky considered whether stigma damages in a property casualty case are recoverable in addition to the costs incurred to remediate the actual damage. The...more

Jones Day

Bankruptcy Court Rules "Make-Whole" Provision Creates Enforceable Liquidated Damages

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The Situation: After a ruling in In re Ultra Petroleum Corp. by the U.S. Bankruptcy Court for the Southern District of Texas, certain private-placement noteholders are entitled to a "make-whole" premium in excess of $200...more

Morgan Lewis

Ultra Court Confirms Make-Whole Amount and Post-Petition Interest for OpCo Noteholders

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The court awarded OpCo Noteholders in excess of $320 million in Make-Whole Amount and post-petition interest, confirming that make-whole is an enforceable liquidated damage claim....more

Katten Muchin Rosenman LLP

Language Matters: Third Circuit Finds Make-Whole Provision Enforceable After Bankruptcy Filing

On November 17, 2016, the US Court of Appeals for the Third Circuit in Delaware Trust Co. v. Energy Future Intermediate Holding Co. LLC, No. 16-1351 (3d Cir. Nov. 17, 2016) clarified the often-muddy interplay between...more

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