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Preemption Bankruptcy Code

Jones Day

Boston Generating: Second Circuit Triples Down on Its Holding that Transfers Made Under Securities Contracts Are Safe Harbored in...

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Section 546(e) of the Bankruptcy Code's "safe harbor" provision (which shields transactions from avoidance claims in bankruptcy of certain securities, commodity, or forward-contract payments) has long been a magnet for...more

Dorsey & Whitney LLP

The Supreme Court Update - October 16, 2023

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On October 13, 2023, the Supreme Court of the United States granted certiorari in 4 cases: Relentless, Inc. v. Department of Commerce, 22-1219: This is the second case that the Court has agreed to hear this term...more

Kaufman & Canoles

Credit Union Client Alert - September 2023

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In a recently published opinion by Fourth Circuit Judge Quattlebaum, Jr., the majority of the panel found there to be a genuine dispute of material fact in Plaintiff Mark Anthony Guthrie’s North Carolina Debt Collection Act...more

Jones Day

New York District Court Expands the Scope of the Bankruptcy Safe Harbor for LBO Payments

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In 2019, the U.S. Court of Appeals for the Second Circuit made headlines when it ruled that creditors' state law fraudulent transfer claims arising from the 2007 leveraged buyout ("LBO") of Tribune Co. ("Tribune") were...more

Kramer Levin Naftalis & Frankel LLP

New York’s Highest Court Finds That Federal Bankruptcy Law Does Not Preempt State Law Tortious Interference Claims in Important...

On Nov. 24, 2020, the State of New York Court of Appeals ruled in favor of Kramer Levin client Sutton 58 Associates LLC (Sutton), an affiliate of Gamma Real Estate, in its $100 million lawsuit brought against real estate...more

Jones Day

Expanding the Scope of the Bankruptcy Safe Harbor for Securities Transactions

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In 2019, the U.S. Court of Appeals for the Second Circuit made headlines when it ruled that creditors' state law fraudulent transfer claims arising from the 2007 leveraged buyout ("LBO") of Tribune Co. ("Tribune") were...more

A&O Shearman

Can a Corporate Debtor Be a ‘Financial Institution’? Second Circuit Again Holds That Tribune’s LBO is Protected By the Bankruptcy...

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On December 19, 2019, the Second Circuit held that appellants’ state law constructive fraudulent transfer claims were preempted by virtue of the Bankruptcy Code’s safe harbors that exempt transfers made in connection with a...more

Carlton Fields

Should I Stay or Should I Go? Bankruptcy Preemption May Bar FDCPA and FCCPA Claims Either Way

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After receiving a bankruptcy discharge, a borrower whose home is pending foreclosure has two options: stay in the home and, perhaps, make voluntary payments on the mortgage, or leave the home and start fresh. When a debt...more

Skadden, Arps, Slate, Meagher & Flom LLP

District Court Applies Section 546(e) Safe Harbor to Customer of Financial Institution, Revitalizing Key Defense

A recent decision from the U.S. District Court for the Southern District of New York has breathed new life into the Bankruptcy Code Section 546(e)’s securities transaction safe harbor for fraudulent conveyance actions. Judge...more

Kramer Levin Naftalis & Frankel LLP

Delaware Bankruptcy Court Upholds Bankruptcy Code Pre-emption Invalidating Pre-Petition Claims as Part of Post-Petition KERP

The Delaware Bankruptcy Court, in In re Old BPSUSH Inc., Case No. 16-12373 (Bankr. Del. June 1, 2018) [Docket No. 1787], upheld provisions in a post-petition key employee retention plan (KERP) that provided for a waiver of...more

Patterson Belknap Webb & Tyler LLP

Major Section 546(c) Safe Harbor Issue Resolved by the Supreme Court

Our post last year concerning “[t]he long-running litigation spawned by the leveraged buyout of Tribune Company . . . and the subsequent bankruptcy case” described a case--FTI v. Merit--that was then pending in the Supreme...more

Dorsey & Whitney LLP

The Supreme Court - May 15, 2017

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Midland Funding, LLC v. Johnson, No. 16-348: Respondent Aleida Johnson filed for Chapter 13 bankruptcy in the Southern District of Alabama. Petitioner Midland Funding then filed a “proof of claim” in the Bankruptcy Court,...more

A&O Shearman

Not So Safe After All?

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United States Bankruptcy Court for the District of Delaware Holds That Litigation Trustee May Pursue State Law Fraudulent Conveyance Claims, Notwithstanding Bankruptcy Code Safe Harbors - On June 20, 2016, the United...more

Troutman Pepper Locke

Does Federal Bankruptcy Law Preempt State Law Fraudulent Transfer Claims Assigned to a Bankruptcy Estate Representative?

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The U.S. Bankruptcy Court for the District of Delaware recently issued an opinion that addresses, among other issues, the question of whether section 546(e) of the Bankruptcy Code preempts certain fraudulent transfer...more

Dorsey & Whitney LLP

The Supreme Court - June 2016 #3

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The Supreme Court of the United States issued decisions in three cases on June 13, 2016: - Puerto Rico v. Franklin Cal. Tax-Free Trust, No. 15-233: Under the Federal Bankruptcy Code, state bankruptcy laws that enable...more

Faegre Drinker Biddle & Reath LLP

Supreme Court Decides Commonwealth of Puerto Rico v. Franklin California Tax-Free Trust

On June 13, 2016, the Supreme Court of the United States decided Commonwealth of Puerto Rico v. Franklin California Tax-Free Trust, No. 15-233, holding that Chapter 9 of the federal bankruptcy code preempts Puerto Rico’s...more

Mintz - Public Finance Viewpoints

Three Strikes and Recovery Act is Out

Today’s U.S. Supreme Court decision in Commonwealth of Puerto Rico v. Franklin California Tax-Free Trust puts an end to one of Puerto Rico’s multi-pronged efforts to deleverage itself. Given the comprehensiveness of the...more

A&O Shearman

Making the Safe Harbors Safe Again - United States Court of Appeals for the Second Circuit Holds That State Law Constructive...

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The Bankruptcy Code contains “safe harbors” that, among other things, exempt transfers made in connection with certain financial contracts, including securities contracts, from avoidance by the bankruptcy trustee as...more

Alston & Bird

Bankruptcy & Financial Restructuring/Finance Advisory: Second Circuit Rejects Potential Loophole in the Securities Contract Safe...

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The Second Circuit Court of Appeals recently held that the “safe harbor” protections for securities contracts in Section 546(e) of the Bankruptcy Code prevented individual creditors’ state law constructive fraudulent transfer...more

Mintz - Bankruptcy & Restructuring Viewpoints

Tranquil Waters Once Again in the Safe Harbor: Bankruptcy Safe Harbor Protects Shareholders From State Constructive Fraud Claims

Shareholders who received nearly $8 billion from the Tribune Company leveraged buyout (LBO) do not have to give back that money as a constructive fraudulent transfer. Although the possibility remains that the creditors can...more

Latham & Watkins LLP

Ever-Expanding Safe Harbor Leaves Creditors’ Claims Stranded at Sea

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Second Circuit holds that Bankruptcy Code preempts creditors’ state law constructive fraud claims. On March 29, 2016, the Second Circuit issued its opinion in In re Tribune Company Fraudulent Conveyance Litig.,...more

McGuireWoods LLP

Second Circuit Rules that Bankruptcy Safe Harbor Preempts State Law Fraudulent Transfer Rights

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Today, the Second Circuit reissued the latest in a line of cases adopting an expansive reading of the safe harbor under Section 546(e) of the Bankruptcy Code. In re Tribune Co. Fraudulent Conveyance Litig., Case 13-3992, Doc....more

Womble Bond Dickinson

NHL Scores Big on Attorneys' Fees Against Nondebtors

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Last fall, the National Hockey League (NHL) enjoyed a big off-ice victory when the U.S. District Court for the District of Arizona found that it was entitled to recover from Jerry and Vickie Moyes and the Jerry and Vickie...more

Burr & Forman

M.D. Fla. Holds Bankruptcy Code Preempts FDCPA For Filing Time Barred Proofs of Claim

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In Castellanos v. Midland Funding, LLC, 15-CV-559 (M.D. Fla. Jan. 4, 2016) the United States District Judge John Steele joined with several of his Middle District of Florida colleagues and held that the Bankruptcy Code...more

Orrick, Herrington & Sutcliffe LLP

Distressed Download - July 2015

First Circuit Rules Bankruptcy Code Preempts Puerto Rico's Recovery Act - On Monday, July 6, the Court of Appeals for the First Circuit affirmed the February 6, 2015 order and injunction of the Puerto Rico District...more

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