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Delaware Bankruptcy Court Clarifies Broad Scope of Fraudulent Transfer Claims

The US Bankruptcy Court for the District of Delaware recently reaffirmed but limited the holding of In re DSI Renal Holdings, LLC, which held that under Third Circuit law, neither debtors nor trustees could bring fraudulent...more

SDNY Bankruptcy Court Holds that “Opt-Out” Mechanism Renders Third-Party Releases Consensual in Spirit Airlines Chapter 11 Plan

The US Bankruptcy Court for the Southern District of New York (the Court) recently approved third-party releases contained in a chapter 11 plan (the Plan) and found that, under the facts and circumstances, the opt-out...more

US Bankruptcy Court Denies Stalking Horse Bidder’s Motion to Disregard Late Filed Overbids

In re Parkcliffe Development, LLC, Case No. 24-30814 - The US Bankruptcy Court for the Northern District of Ohio in In re Parkcliffe Development, LLC, Case No. 24-30814 (JPG) entered an order on January 28, 2025 denying a...more

US Bankruptcy Court Grants Motion to Dismiss LLC Chapter 11 Case for Failure to Obtain Requisite Corporate Filing Authority

The US Bankruptcy Court for the Northern District of Illinois (Bankruptcy Court) recently issued an opinion in In re 301 W North Avenue, LLC, Case No. 24 B 2741 (DDC) [Docket No. 253] (January 6, 2025) granting a secured...more

Fifth Circuit Rules that Serta Simmons Bedding, LLC’s 2020 Uptier Transaction Violated Pro Rata Distribution Covenant

In a landmark ruling, the US Court of Appeals for the Fifth Circuit ruled that a June 2020 refinancing transaction (the Uptier Transaction) entered by Serta Simmons Bedding, LLC (SSB, or the Debtor) and certain of its lenders...more

SDNY Bankruptcy Court Approves Settlement Agreements with Nonconsensual Third-Party Releases for Insurance Companies

In the chapter 11 bankruptcy case of In re Roman Catholic Diocese of Rockville Centre, New York, Case No. 20-12345 (MG), the US Bankruptcy Court for the Southern District of New York recently approved settlement agreements...more

US Bankruptcy Court rules on lease classification for skilled nursing and long-term care facilities

The US Bankruptcy Court for the Western District of Pennsylvania issued a memorandum opinion on November 15, 2024, holding that a real property lease for a skilled nursing, long-term care, and rehabilitation facility should...more

US Bankruptcy Court Establishes Guidelines for “New Value” Plans of Reorganization in Competing Plan Scenarios

Introduction - On October 25, 2024, Judge John P. Mastando III of the US Bankruptcy Court for the Southern District of New York issued a ruling in Eletson Holdings Inc., Case No. 23-10322, pursuant to which he (a) denied...more

Second Circuit Rules Bankruptcy Code’s “Safe Harbor” Provision Preempts State Law Fraudulent Transfer Claims

On September 19, 2024, the US Court of Appeals for the Second Circuit issued a summary order in which it held that the “safe harbor” provision of Section 546(e) of the Bankruptcy Code preempted a bankruptcy trustee’s state...more

Ninth Circuit Authorizes Trustees to Avoid Intentional Fraudulent Transfers Without Need to Demonstrate Creditor Harm

In a case of first impression in the Ninth Circuit, the US Court of Appeals recently handed bankruptcy trustees a significant power by ruling in The Lovering Tubbs Trust v. Hoffman (In re O’Gorman) that a trustee can avoid...more

Third Circuit Court Orders Solvent Debtors to Pay Contract Rate Interest, Make-Whole Fees to Unsecured Creditors

Introduction - On September 10, 2024, the US Court of Appeals for the Third Circuit decided in In re Hertz that although make-whole fees are unmatured interest typically disallowed by section 502(b) of the Bankruptcy Code, a...more

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