Two Recent Decisions Demonstrate Continued Disagreement Over Whether Economic Value or Face Amount of Liens Is Appropriate Metric in Authorizing Free and Clear Bankruptcy Sale

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Jones Day

The ability of a trustee or chapter 11 debtor in possession ("DIP") to sell bankruptcy estate assets "free and clear" of liens on the property under section 363(f) of the Bankruptcy Code has long been recognized as one of the most powerful tools for restructuring a debtor’s balance sheet and generating value in bankruptcy. Section 363(f)(3) permits a sale free and clear if "such interest is a lien and the price at which such property is to be sold is greater than the aggregate value of all liens on such property." However, courts disagree as to the meaning of the phrase "the aggregate value of all liens."

Two recent rulings add to the ongoing rift among bankruptcy and appellate courts regarding this issue. In In re Bay Circle Properties, LLC, 2017 BL 44637 (Bankr. N.D. Ga. Feb. 14, 2017), the United States Bankruptcy Court for the Northern District of Georgia determined that a sale of real property free and clear under section 363(f)(3) was permitted because the sale price met or exceeded the economic value of the liens encumbering the property, even though the price did not exceed the face amount of the liens. The United States Bankruptcy Court for the District of New Jersey reached the opposite conclusion in In re Lutz, 2017 BL 147967 (Bankr. D.N.J. May 3, 2017), ruling that "value" in section 363(f)(3) "means the face value of the lien."

Sales Free and Clear Under Section 363(f)

Section 363(f) authorizes a trustee or DIP to sell property "free and clear of any interest in such property of an entity other than the estate" under any one of five specified conditions (only one of which involves consent). A bankruptcy court’s power to order sales free and clear of such interests without the consent of the party asserting the interest has been recognized for more than a century. See Ray v. Norseworthy, 90 U.S. 128, 131–32 (1875); Van Huffel v. Harkelrode, 284 U.S. 225, 227 (1931). Free and clear sales promote the expeditious liquidation of estate assets by avoiding the delay attendant to resolving disputes concerning the validity and extent of liens and other interests, which can later be adjudicated in a centralized forum. They also promote the maximization of the value of estate assets. After all, a prospective buyer would discount its offer for an asset significantly if it were faced with the prospect of protracted litigation to obtain clear title or if it had to accept title subject to liens or other interests. To obtain the benefit of a free and clear sale, section 363(e) of the Bankruptcy Code provides that the nondebtor is entitled to "adequate protection" of its interest, which most commonly takes the form of a replacement lien on the proceeds of the sale.

One of the five alternative conditions—set forth in section 363(f)(3)—to permit a sale free and clear of an interest is that "such interest is a lien and the price at which such property is to be sold is greater than the aggregate value of all liens on such property." 11 U.S.C. § 363(f)(3). The Bankruptcy Code does not elaborate on the meaning of the phrase "aggregate value of all liens" in section 363(f)(3), and two approaches have emerged among courts as to its interpretation in the context of this provision.

Some courts have held that section 363(f)(3) refers to the economic value of a lien, which is determined by the value of the collateral. See, e.g., In re WPRV-TV Inc., 143 B.R. 315 (D.P.R. 1991); In re Boston Generating LLC, 440 B.R. 302 (Bankr. S.D.N.Y. 2010). Under this "Economic Value Approach," courts reason that the term "value" should be given the same meaning in section 363(f) which it has in sections 506(a) and 361 of the Bankruptcy Code.

Section 506(a) provides that the claim of a creditor secured by a lien on the debtor’s property "is a secured claim to the extent of the value of such creditor’s interest in the estate’s interest in such property" and an unsecured claim to the extent that the claim exceeds the value of the collateral. 11 U.S.C. § 506(a). Similarly, section 361 requires "adequate protection" payments to a secured creditor to protect against any "decrease in the value of such entity’s interest" in property under certain circumstances. 11 U.S.C. § 361(1). Thus, both provisions refer to the economic value of the underlying collateral, rather than the face amount of the claim secured by a lien on such collateral.

Courts adopting the Economic Value Approach reason that their interpretation of section 363(f)(3) supports the maximization of value for creditors—one of the central purposes of the Bankruptcy Code—by precluding out-of-the-money lienholders from blocking sales which otherwise would be beneficial to the estate and its stakeholders.

Other courts have held that the language of section 363(f)(3) refers to the aggregate face amount of all liens secured by the property, rather than their economic value. See, e.g., Clear Channel Outdoor, Inc. v. Knupfer (In re PW, LLC), 391 B.R. 25 (B.A.P. 9th Cir. 2008); Criimi Mae Servs. Ltd. P’ship v. WDH Howell LLC (In re WDH Howell LLC), 298 B.R. 527 (D.N.J. 2003). Courts’ principal argument under this "Face Amount Approach" is that the Economic Value Approach can never be satisfied because the sale price determines the value of the property and so must equal (and thus cannot be greater than) the aggregate economic value of the liens (unless the price also exceeds their face value). These courts resist interpreting section 363(f)(3) of the Bankruptcy Code consistently with sections 506(a) and 361 on the basis that those provisions expressly denote economic value by referring to the extent of the lienholder’s or estate’s interest in the property. If Congress intended to refer to the economic value of the lien in section 363(f)(3), these courts suggest, it would have worded the provision similarly.

The bankruptcy courts weighed in on this debate in Bay Circle and Lutz.

Bay Circle

Bay Circle Properties, LLC ("Bay Circle" or the "Debtor") and certain affiliates filed for chapter 11 protection in the Northern District of Georgia on May 4, 2015. Among Bay Circle’s assets were two warehouse buildings (the "Property") in Gwinnett County, Georgia.

In October 2014, Good Gateway, LLC, and SEG Gateway, LLC (together, the "Lienholders") obtained $14.5 million in judgments in Florida state court against Bay Circle’s principal and certain affiliates, none of which later filed for bankruptcy. In December 2014, the Lienholders recorded judgment liens with respect to the Property. Shortly thereafter, Bay Circle’s principal transferred his interest in the Property to Bay Circle, subject to the Lienholders’ liens. The Property also was encumbered by a first-priority lien securing a $22 million loan to Bay Circle (the "Loan"). The Property was not the only collateral for the Loan; obligations under the Loan were further secured by liens on various other assets of Bay Circle and its nondebtor affiliates. Ultimately, Bay Circle commenced a chapter 11 bankruptcy case.

Bay Circle and the first-priority secured lender, which later assigned its Loan to Bay Point Capital Partners, LP (the "Lender"), entered into a settlement agreement that was approved by the bankruptcy court. Among other things, the agreement: (a) required the Debtor to make "milestone payments" to the Lender; and (b) specified minimum sale prices—or "release prices"—for the collateral, including a $5 million release price for the Property. The agreement also provided that, upon default, the Lender could foreclose on the Property by means of a nonjudicial foreclosure under Florida law.

The bankruptcy court denied the Debtor’s motion to refinance the debt on the Property so that it could make a $3.5 million milestone payment. The Debtor responded by filing an emergency motion to sell the property at auction, free and clear of liens (including the Lienholders’ junior liens) under section 363(f) of the Bankruptcy Code.

The Lender objected, asserting that it had the right to credit bid its secured claim (which at this point had been reduced to $15 million) in any sale of the Property. The Lienholders also objected to the sale, arguing, among other things, that a sale of the property free and clear of their junior liens violated section 363(f)(3) because the face amount of all liens encumbering the property—totaling approximately $30 million—exceeded the anticipated $5 million proceeds from the auction sale. The court ultimately overruled the Lienholders’ objections and approved the sale of the Property at auction to the Lender for a $5.35 million credit bid, effectively stripping the Lienholders’ junior liens from the property.

The bankruptcy court evaluated the ability of the Debtor to sell the Property free and clear of liens under section 363(f). In doing so, it adopted the Economic Value Approach, ruling that section 363(f)(3) requires only that the sale price be greater than or equal to the value of the liens encumbering it, as distinguished from the face value of the secured claims asserted against it. The court concluded that the plain language of the statute supports using economic value as a metric. Section 363(f)(3), the court wrote, plainly refers to the "value" of the liens, "not the amount of the liens." In addition, the court reasoned that section 363(f)(3) would be superfluous if it were construed to require payment in full of the face amount of all liens, noting that "a sale which results in the payment in full of the liens, of course, is free and clear of them."

The court explained that the Lienholders’ liens had no economic value because the Lender’s senior lien on the property exceeded $15 million on a property worth much less than that. Noting that the Debtor scheduled the value of the warehouse property at $5.5 million, and the Lender’s minimum release price for the property was $5.0 million, the court concluded that the $5.35 million auction price "meets or exceeds" the economic value of the Lender’s lien. Thus, the court ruled that section 363(f)(3) had been satisfied.


After separately filing for chapter 11 protection in the District of New Jersey in 2016, Richard and Susan Lutz (the "Lutzes") filed a motion to sell their jointly owned Moorestown, New Jersey, real property for $1.3 million, free and clear of liens under section 363(f). The property was encumbered by a mortgage held by a lender (the "Mortgagee") that filed a secured claim in the amount of approximately $2.4 million.

The Mortgagee objected to the sale free and clear of its lien, arguing that the sale could not satisfy section 363(f)(3) because the anticipated sales price for the property was not greater than the face value of its lien. The Lutzes contended that "value" in section 363(f)(3) should mean "economic value," which they argued is the "actual value to be determined by the Court."

The bankruptcy court noted that the United States District Court for the District of New Jersey rejected the Lutzes’ interpretation of "value" in the Howell case. In Howell, the district court employed a common sense analysis of the plain language of section 363(f)(3) to determine congressional intent. It ruled that "value" cannot mean "economic value" when read in the context of the preceding phrase "greater than" because "the sale price for the overencumbered property can never be greater than the aggregate economic value of the liens on the property." Howell, 298 B.R. at 532 (citation omitted).

The Lutz court found Howell to be persuasive, ruling that the term "value" in section 363(f)(3) means the face value of the lien. The court accordingly held that the property could not be sold free and clear of the Mortgagee’s lien under section 363(f)(3) because the proposed sale price was less than the face value of the lien.


Bay Circle and Lutz do little to end the debate on the meaning of section 363(f)(3) of the Bankruptcy Code. The cases’ dramatic differences in approach and outcome reflect the courts’ continuing struggle to interpret a provision that is commonly relied on in bankruptcy cases to facilitate quick asset sales which generate much-needed value for the estate.

This struggle is understandable. Although there is logic to the Economic Value Approach, it does not squarely comport with the language of section 363(f)(3), which allows sales free and clear of liens only where "the price at which such property is to be sold is greater than the aggregate value of all liens on such property." Arguably, this language can never be satisfied where there are underwater liens—a common situation in bankruptcy—because a market sale price will never "exceed" the value of liens. The Bay Circle court apparently reads the statute to include sales "equal to or greater than" the value of liensa practical approach that by necessity reframes the statutory language to allow lienholders to realize the value of their liens and no more, consistent with other provisions of the Bankruptcy Code.

Considering itself constrained by the plain language of section 363(f)(3), the Lutz court joined those courts that have adopted the alternative Face Amount Approach. The Bay Circle court makes a strong point, however, that the Face Amount Approach renders section 363(f)(3) a virtual nullity (i.e., a debtor may pay off liens at face value without the help of the Bankruptcy Code) and seems to assign value to valueless liens (i.e., a debtor may not sell free and clear of underwater liens under section 363(f)(3) if the sale price does not pay them in full). Absent congressional clarification to the statutory language, the resolution of this debate may require more rulings at the appellate level.

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