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§ 1129(b)(2)

Friedman v. PP LLC (In re Friedman)

Ruling
Denial of confirmation and conversion to chapter 7 reversed as bankruptcy court improperly applied the absolute priority rule in an individual chapter 11 case.
Procedural posture

Appellant chapter 11 debtors challenged a decision of the Bankruptcy Court for the District of Arizona, which denied confirmation of their second amended plan and converted their case to chapter 7.

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Court :
Judge or Jurisdiction information not available
Consumer opinion summary, case decided on March 19, 2012 , LexisNexis #0512-031

In re Cottonwood Corners Phase V LLC

Ruling
Confirmation denied due to imposition of subordination agreement on creditor landlord without consent.
Procedural posture

A chapter 11 debtor sought confirmation of its plan of reorganization, which was opposed by its largest creditor.

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Commercial opinion summary, case decided on February 17, 2012 , LexisNexis #0312-060

In re Lively

Ruling
Confirmation denied due to continued operation of absolute priority rule.
Procedural posture

After a bankruptcy court preliminarily announced that it would deny confirmation of a chapter 11 individual plan for violating 11 U.S.C.S. § 1129(b)(2)(B)(ii), it allowed briefings on the question of whether the Bankruptcy Abuse and Consumer Protection Act of 2005 (BAPCPA) abrogated the absolute priority rule for individual chapter 11 cases.

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Consumer opinion summary, case decided on December 30, 2011 , LexisNexis #0212-030

In re Olde Prairie Block LLC

Ruling
Plan that would allow debtor to retain property free and clear of creditor's lien could not be confirmed over creditor's objection.
Procedural posture

A secured creditor filed a motion to dismiss a chapter 11 debtor's updated third amended plan of reorganization on the grounds that the plan contained at least four per se violations of the confirmation requirements of 11 U.S.C.S. § 1129.

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Commercial opinion summary, case decided on December 23, 2011 , LexisNexis #0212-062

In re Profl Veterinary Prods.

Ruling
Objection to confirmation sustained due to failure to provide secured creditor with indubitable equivalent of value of claim.
Procedural posture

In a chapter 11 case, a creditor objected to its treatment in the debtor's plan.

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Commercial opinion summary, case decided on December 16, 2011 , LexisNexis #0112-096

In re Walkabout Creek Ltd. Dividend Hous. Assn Ltd. Pship

Ruling
Confirmation of plan proposing reamortization of loans at low rate denied due to lack of feasibility.
Procedural posture

Affiliated debtors which owned low-income apartment complexes financed by a state housing agency proposed plans which provided that the agency was fully secured and that the agency loans would be reamortized with interest at a stated rate. The agency objected to confirmation of the debtors' plans.

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Commercial opinion summary, case decided on November 14, 2011 , LexisNexis #1211-096

SPCP Group LLC v. Norton

Ruling
Absolute priority rule did not apply to prevent individual chapter 11 debtor from retaining property over objection of unsecured creditor.
Procedural posture

Appellant, appellee debtors' largest unsecured creditor, challenged a decision of the U.S. Bankruptcy Court for the Middle District of Florida, which confirmed the plans of reorganization of the debtors.

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Consumer opinion summary, case decided on September 21, 2011 , LexisNexis #1011-100

In re SUD Props.

Ruling
Confirmation denied where plan treatment of creditor did not provide indubitable equivalent of secured claim.
Procedural posture

Debtor, a single asset real estate case as defined in 11 U.S.C.S. § 101(51B), filed a second petition for relief under chapter 11, and submitted a plan for confirmation, proposing to transfer certain secured parcels to the secured creditor in a partial "dirt for debt" plan. The creditor objected, asserting that it did not receive fair and equitable treatment under 11 U.S.C.S. § 1129(b)(2)(A)(iii).

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Commercial opinion summary, case decided on August 23, 2011 , LexisNexis #0112-097

In re Lindsey

Ruling
Confirmation denied due to violation of the absolute priority rule.
Procedural posture

Creditor banks filed objections, asserting that debtor in possession's first amended plan of reorganization could not be confirmed as a matter of law because it allowed the debtor to retain pre-petition property in violation of the absolute priority rule of 11 U.S.C.S. § 1129(b)(2)(B)(ii). The creditors moved for summary judgment.

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Consumer opinion summary, case decided on August 05, 2011 , LexisNexis #0911-062

River Rd. Hotel Partners LLC v. Amalgamated Bank

Ruling
Denial of asset sale procedure that did not allow credit bids by secured creditors affirmed.
Procedural posture

Debtors challenged a decision of the U. S. Bankruptcy Court for the Northern District of Illinois, which denied the bid procedures motions that they filed in connection with their chapter 11 reorganization plans.

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Court :
Judge or Jurisdiction information not available
Commercial opinion summary, case decided on June 28, 2011 , LexisNexis #0711-096