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Section 363 Bankruptcy Code Chapter 11

Lowenstein Sandler LLP

Bankruptcy in Real Estate: What to Do When Faced with Foreclosure?

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This episode of “Terra Firma: Conversations on Commercial Real Estate” features hosts Stacey C. Tyler and Stephen Tanico talking with Eric Chafetz, partner in Lowenstein’s Bankruptcy and Restructuring Group, about office...more

Jones Day

Fifth Circuit: Recent U.S. Supreme Court Ruling Did Not Alter Mootness Requirements for Unstayed Bankruptcy Sale Orders

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Section 363(m) of the Bankruptcy Code offers powerful protection for good-faith purchasers in bankruptcy sales because it limits appellate review of an approved sale, irrespective of the legal merits of the appeal....more

Nelson Mullins Riley & Scarborough LLP

The Fifth Circuit Joins the Eighth and Ninth Circuits in Holding that Avoidance Actions are Estate Property that may be Sold...

In an opinion on January 22nd, the Fifth Circuit Court of Appeals, in Matter of S. Coast Supply Co., 91 F.4th 376 (5th Cir. 2024), held that preference claims arising under 11 U.S.C. § 547 may be sold, reversing the dismissal...more

Vinson & Elkins LLP

5th Circuit: Section 363(m) Mootness is Alive and Well

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On February 20, 2024, the United States Court of Appeals for the Fifth Circuit issued an Opinion, which held that challenges to “integral” aspects of a bankruptcy sale are statutorily moot under Bankruptcy Code § 363(m). In...more

Jones Day

Texas District Court: Equitable Mootness Doctrine Does Not Preclude Appellate Review of Chapter 11 Plan Exculpation Clause

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Exculpation clauses limiting the liability of certain entities for actions taken in connection with a bankruptcy case are a common feature of chapter 11 plans. However, courts disagree over the permitted scope of such...more

Jones Day

U.S. Supreme Court Rules that Bankruptcy Code's Protection of Unstayed Asset Sale Orders to Good-Faith Purchasers Is Not...

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Section 363(m) of the Bankruptcy Code provides that the reversal or modification of an order approving a sale or lease of assets in bankruptcy does not affect the validity of the sale or lease to a good-faith purchaser or...more

Greenberg Glusker LLP

The Effective Use of Section 363 sales

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When a company is not likely to survive a restructuring, its assets may have value to a third-party buyer. Absent legal protection, a buyer of a financially distressed business will usually be concerned that the company’s...more

Fox Rothschild LLP

How Safe Is Your 363(m) Sale? The Supreme Court’s Invalidation of Statutory Mootness is a Risk to Asset Purchasers Seeking...

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On April 19, 2023, Justice Ketangi Brown Jackson, writing for a unanimous Court in MOAC Mall Holdings LLC v. Transform Holdco LLC et.al., 598 U.S. ___ 143 S. Ct. 927 (2023), held that Bankruptcy Code section 363(m) is not...more

Polsinelli

The MOAC Decision: Implications for DIP Lenders, Not Just for Asset Purchasers

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The Supreme Court’s April 19, 2023, decision in MOAC Mall Holdings, LLC v. Transform Holdco, LLC, 598 U.S.­­­___, ___S. Ct.___, 2023 WL 2992693 (April 19, 2023) resolved an existing circuit split by holding that section...more

Miller Canfield

Supreme Court Rules That Section 363(m) Protections for a Bankruptcy Sale Are Not Jurisdictional

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On April 19, 2023, the Supreme Court issued its opinion in MOAC Mall Holdings, LLC v. Transform Holdco, LLC. The decision has implications for sales of property in bankruptcy cases. Section 363(m) of the Bankruptcy Code...more

Jones Day

U.S. Supreme Court Rules Appellate Protection of Bankruptcy Property Sale Is Subject to Waiver and Estoppel

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In Short - The Situation: The U.S. Supreme Court considered whether § 363(m) of the Bankruptcy Code, which limits a party's ability to undo an asset transfer made to a good-faith purchaser in a bankruptcy case, is...more

Cadwalader, Wickersham & Taft LLP

United States Supreme Court Holds that Bankruptcy Code Section 363(m) Does Not Preclude Appellate Jurisdiction on Asset Sale...

In a ruling issued just yesterday, MOAC Mall Holdings LLC v. Transform Holdco LLC et al., 598 U.S. ----, 2023 WL 2992693 (2023) (“MOAC”), the United States Supreme Court (the “Supreme Court”) held that Bankruptcy Code section...more

Faegre Drinker Biddle & Reath LLP

Supreme Court Decides MOAC Holdings LLC v. Transform Holdco LLC, et al.

On April 19, 2023, the United States Supreme Court issued a unanimous decision in MOAC Mall Holdings LLC v. Transform Holdco LLC et al., No. 21–1270, holding 11 U.S.C. § 363(m) of the Bankruptcy Code is not a jurisdictional...more

Jones Day

Appeal of Unstayed Order Approving Bankruptcy Sale of Real Property Free and Clear of Lease and Related Settlement Agreement...

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To promote the finality of bankruptcy asset sales, section 363(m) of the Bankruptcy Code "moots" an appeal of an order approving a sale to a good-faith purchaser unless the party challenging the sale obtains a stay pending...more

Spilman Thomas & Battle, PLLC

SCOTUS and Bankruptcy Orders – Considering Jurisdiction and Impact

The U.S. Supreme Court recently heard arguments in MOAC Mall Holdings LLC v. Transform Holdco LLC. The case involves the authority of a court of appeals to review a bankruptcy order authorizing a bankrupt tenant to sell its...more

Jones Day

Debtor Can Sell Assets Free and Clear of Successor Liability Claims Asserted by Union Pension Funds

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The ability of a bankruptcy trustee or chapter 11 debtor-in-possession to sell assets of the bankruptcy estate "free and clear" of "any interest in property" asserted by a non-debtor is an important tool designed to maximize...more

Jones Day

Texas District Court: Bankruptcy Sale Break-Up Fee Satisfied Both Business Judgment Test and Administrative Expense Standard

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Bankruptcy and appellate courts disagree over the standard that should apply to a request for payment of a break-up fee or expense reimbursement to the losing bidder in a sale of the debtor's assets outside the ordinary...more

Nelson Mullins Riley & Scarborough LLP

Bankruptcy 101: 363 Sales Bankruptcy Basics for New and Non-Bankruptcy Attorneys

This entry is part of Nelson Mullins’s ongoing “Bankruptcy Basics” blog series that is intended to address foundational aspects of bankruptcy for non-bankruptcy practitioners and professionals. This entry will discuss sales...more

Jones Day

Buyer's Bad Faith in Failing to Inform Court of Right of First Refusal Precludes Statutory Mootness of Bankruptcy Sale

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The finality of asset sales in bankruptcy is an indispensable feature of U.S. bankruptcy law designed to maximize the value of a bankruptcy estate as expeditiously as possible for the benefit of all stakeholders. To promote...more

Vinson & Elkins LLP

Section 363(m) Circuit Split Headed for SCOTUS Review

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The Supreme Court of the United States granted certiorari on June 27, 2022, to determine whether section 363(m) of the Bankruptcy Code—concerning appellate review of bankruptcy court sale orders—is jurisdictional or only...more

Proskauer Rose LLP

Private Credit Lenders: What’s a “Structured Dismissal” and Why Should You Care?

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Despite the Supreme Court’s rejection of a structured dismissal in 2017, there is a growing trend of bankruptcy courts approving structured dismissals of chapter 11 cases following a successful sale of a debtor’s assets under...more

Dorsey & Whitney LLP

Weinstein Case Demonstrates Difficulties in Following Complex Bankruptcy Sales

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Everyone is likely familiar with the chapter 11 bankruptcy of The Weinstein Company (“TWC“), an former film and production studio that previously produced and distributed featured films and premium television content...more

Greenberg Glusker LLP

License Rights and Bankruptcy: No “Silver Linings”

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The Third Circuit’s decision in Spyglass Media Company v. Cohen has added to what is already a tangled web of cases dealing with the rights of licensees and licensors when one of them becomes a debtor in bankruptcy. In...more

Patterson Belknap Webb & Tyler LLP

The Best Laid Plans: How a Proposed Sale of NYC Real Estate Under Section 363 of the Bankruptcy Code Went Awry

There are several ways in which property owners can advantageously use the Bankruptcy Code to effectuate strategic dispositions of assets. But the bankruptcy process can be fraught with uncertainty that can upend the best...more

Jones Day

Assets May Be Sold in Bankruptcy Free and Clear of Successor Liability

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The ability of a bankruptcy trustee or chapter 11 debtor-in-possession ("DIP") to sell assets of the bankruptcy estate "free and clear" of "any interest" in the property asserted by a non-debtor is an important tool designed...more

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