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Fraudulent Transfers Bankruptcy Code Supreme Court of the United States

Jones Day

U.S. Supreme Court Rules that Bankruptcy Code Provides Only Limited Abrogation of Sovereign Immunity to Avoidance Actions

Jones Day on

Bankruptcy trustees and chapter 11 debtors-in-possession ("DIPs") frequently seek to avoid fraudulent transfers and obligations under section 544(b) of the Bankruptcy Code and state fraudulent transfer or other applicable...more

Rivkin Radler LLP

Supreme Court Decision Limits Trustees’ Ability to Pursue Fraudulent Transfer Actions

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The Supreme Court recently issued an opinion, resolving a circuit split, narrowing the sovereign immunity exception by limiting a trustee’s ability to pursue avoidance actions against the government when such action invokes...more

Nelson Mullins Riley & Scarborough LLP

Supreme Court Limits Trustee Avoidance Powers in U.S. v. Miller - Section 106(a) Doesn’t Waive Sovereign Immunity for...

Section 106(a) Doesn’t Waive Sovereign Immunity for State-Law-Based Section 544(b) Claims - The U.S. Supreme Court has significantly curtailed bankruptcy trustees’ powers in United States v. Miller, 145 S. Ct. 839 (2025). In...more

Tarter Krinsky & Drogin LLP

The Supreme Court Limits A Trustee’s Rights To Recover Fraudulent Transfers Against The Internal Revenue Service

The Bankruptcy Code provides chapter 7 trustees with significant powers to liquidate and collect estate assets and pursue litigation claims, such as fraudulent transfer claims against third parties, all to increase the...more

Ballard Spahr LLP

Supreme Court: No Strong-Arming the Federal Government With State-Law Fraudulent Transfer Claims

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Recently, in the case United States v. Miller, the U.S. Supreme Court held that the sovereign immunity waiver provision in the Bankruptcy Code is jurisdictional only and does not waive the federal government’s sovereign...more

Cadwalader, Wickersham & Taft LLP

Taking Apart Section 544(b): Supreme Court Clarifies Scope of Sovereign Immunity in Avoidance Actions

On March 26, 2025, the Supreme Court held in an 8‑to‑1 decision authored by Justice Ketanji Brown Jackson that Section 106(a) of the Bankruptcy Code waives the federal government’s sovereign immunity with respect to...more

Nelson Mullins Riley & Scarborough LLP

United States v. Miller Oral Argument: Supreme Court Justices Seem Divided on Issues of Allowing a Trustee to Sue the IRS for...

This author previously wrote an article published in Bloomberg Law regarding the Supreme Court’s decision to take up an appeal of a decision on the Tenth Circuit Court of Appeals in United States v. Miller. In Miller, the...more

Morgan Lewis

Tribune: Lessons Learned and Relearned

Morgan Lewis on

This is how Tribune ends: not with a bang, but a whimper. The 12-year litigation saga, rooted in the spectacular failure of the media and sports conglomerate’s 2007 leveraged buyout, reached an end in late February with a...more

Fox Rothschild LLP

Not all Forced-Sale Mortgage Foreclosures are Exempt from Avoidance as Fraudulent Transfers Under Section 548 – a Case Study...

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The United States Supreme Court held in BFP v. Resolution Trust, that properties sold at “force-sale” mortgage foreclosure sales properly conducted pursuant to a state’s foreclosure statute are presumed to have been sold for...more

Jones Day

Tribune District Court Rules That LBO Payments May Not Be Avoided Because Debtor Was "Customer" of "Financial Institution"

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In In re Tribune Co. Fraudulent Conveyance Litig., 2019 WL 1771786 (S.D.N.Y. Apr. 23, 2019), the U.S. District Court for the Southern District of New York denied a litigation trustee’s motion to amend a complaint seeking to...more

Mintz - Bankruptcy & Restructuring Viewpoints

The Delaware Bankruptcy Court Grapples With Section 546(e) Post-Merit Management

In its ruling in FTI Consulting, Inc. v. Sweeney (In re Centaur, LLC), the United States Bankruptcy Court for the District of Delaware addressed the Supreme Court’s recent clarification of the scope of Bankruptcy Code Section...more

Jones Day

From the Top in Brief

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On April 3, 2018, the U.S. Supreme Court issued an order that, in light of its recent ruling in Merit Management Group LP v. FTI Consulting Inc., 138 S. Ct. 883, No. 16-784 (Feb. 27, 2018), the Court would defer consideration...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

Bankruptcy Code’s Safe Harbor Defense Eliminated by Supreme Court; Variant Defense May Survive

In a unanimous decision in Merit Mgmt. Grp., LP v. FTI Consulting, Inc., the U.S. Supreme Court addressed the scope of a Bankruptcy Code exception to the “avoiding powers” of a bankruptcy trustee or Chapter 11...more

Kelley Drye & Warren LLP

Supreme Court Displays More Pragmatic Approach to the Bankruptcy Code in Merit Management v. FTI Consulting

The Supreme Court’s recent decision in Merit Management Group, LP v. FTI Consulting, Inc. has appropriately drawn significant attention. The Court, by narrowing the “safe harbor” provision of Section 546(e) of the Bankruptcy...more

Cole Schotz

The Supreme Court Clarifies The Scope Of Section 546(E)’S Safe Harbor For Securities Related Transactions In Merit Management...

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The Bankruptcy Code gives a bankruptcy trustee, or the debtor in possession, the power to “avoid” certain transfers made by the debtor at various times before filing for bankruptcy relief. Congress provided a number of...more

Jones Day

U.S. Supreme Court Narrows Scope of Section 546(e)’s Safe Harbor for Securities Transaction Payments

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On February 27, 2018, the U.S. Supreme Court issued a highly anticipated ruling resolving a long-standing circuit split over the scope of the Bankruptcy Code’s "safe harbor" provision exempting certain securities transaction...more

Latham & Watkins LLP

Supreme Court’s Merit Management Ruling Highlights Potential Alternative Path to Safe Harbor

Latham & Watkins LLP on

Possible application of Section 101(22)(A) to safe harbor’s covered entity requirement raises important questions for future transferee defendants. Key Points: ..Merit Management raises the possibility that customers of...more

Hogan Lovells

Supreme Court Narrows Scope of Safe Harbor Exception for Securities Clawbacks

Hogan Lovells on

On February 27, 2018, the U.S. Supreme Court resolved a circuit split under the Bankruptcy Code and determined that where funds passed through financial institutions acting as payment conduits, where the ultimate transfer...more

Clark Hill PLC

Dodging the Issue: The Supreme Court "Weighs" In On Bankruptcy Law

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The Supreme Court has been unusually busy in addressing bankruptcy-related matters by issuing two recent opinions – Merit Management Group, L.P. v. FTI Consulting, Inc. (“Merit”) and U.S. Bank, N.A., as Trustee v. Village at...more

Troutman Pepper Locke

Supreme Court Narrows Applicability of Bankruptcy Code's Safe Harbor for Securities-Related Transfers

Troutman Pepper Locke on

In a case that could have significant, long-term ramifications for the holders of stock and other securities, the U.S. Supreme Court vastly limited the scope of a Bankruptcy Code “safe harbor” that shields certain transfers...more

Neal, Gerber & Eisenberg LLP

Supreme Court Limits Safe Harbor Defense in Bankruptcy "Clawback" Suits

Recently, the United States Supreme Court decided Merit Management Group, LP v. FTI Consulting, Inc., a decision that has potentially far-reaching implications for a broad range of business transactions, particularly...more

Cooley LLP

Blog: Safe Harbor Rule Narrowed: Supreme Court Opens Door for Possible Avoidance of Previously Protected Transactions

Cooley LLP on

Over the last twenty years, courts have increasingly insulated transactions from avoidance as fraudulent transfers by invoking the so-called “settlement payment” defense codified in section 546(e) of the Bankruptcy Code. The...more

Jones Day

High Court Tightens Section 546(e) Safe Harbor for Securities Transaction Payments

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The U.S. Supreme Court issued a highly anticipated ruling resolving a long-standing circuit split over the scope of the Bankruptcy Code's "safe harbor" provision exempting certain securities transaction payments from...more

A&O Shearman

Not So Safe: The Supreme Court Clarifies the Scope of the Bankruptcy Code’s Section 546(e) Safe Harbor Provision

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Section 546(e) of the Bankruptcy Code shields certain transfers involving settlement payments and other payments in connection with securities contracts (for example, payment for stock) made to certain financial...more

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