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§ 1129(b)(2)(A)

RadLAX Gateway Hotel LLC v. Amalgamated Bank

Ruling
Plan that stripped a secured creditor of its right to credit bid at a sale of its collateral could not be confirmed.
Procedural posture

A bankruptcy court denied petitioner debtors' request to confirm a "cramdown" bankruptcy plan over respondent lienholder bank's objection, finding that a proposed auction to sell the encumbered asset free and clear of a lien without permitting the bank to credit-bid did not comply with 11 U.S.C.S. § 1129(b)(2)(A)'s requirements for cramdown plans. The U.S. Court of Appeals for the Seventh Circuit affirmed. Certiorari was granted.

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Commercial opinion summary, case decided on May 29, 2012 , LexisNexis #0612-062

In re Kamayan Holdings LLC

Ruling
Plan confirmed over objection where rate paid to creditor exceeded discount cramdown rate and end value would exceed value of creditor's claim.
Procedural posture

Before the court for consideration of confirmation was debtor's plan of reorganization. Debtor's secured creditor objected to the plan.

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Commercial opinion summary, case decided on May 23, 2012 , LexisNexis #0612-063

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 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 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

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

In re Mace

Ruling
Plan proposing 20-year loan repayment period did not discriminate against creditor.
Procedural posture

A creditor objected to confirmation of the second amended plan proposed by a Chapter 11 trustee on the ground that the plan unfairly discriminated against the creditor and that the plan was not fair and equitable as required by 11 U.S.C.S. § 1129(b)(2)(A).

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Consumer opinion summary, case decided on January 25, 2011 , LexisNexis #0211-129

In re Blake

Ruling
Plan confirmed over creditor's objection to using confirmation date as date of valuation for cramdown.
Procedural posture

Bankruptcy debtors proposed a plan which provided that mortgage creditors would receive monthly payments having a present value of the fair market value of the debtors' rental properties on the date of confirmation. The creditors objected to confirmation of the debtors' plan on the ground that the proper date of valuation was the date the debtors commenced their bankruptcy case.

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Consumer opinion summary, case decided on November 30, 2009 , LexisNexis #1209-133

Airdigm Communs. Inc. v. FCC (In re Airdigm Communs. Inc.)

Ruling
Bankruptcy court did not err in awarding post-confirmation interest to FCC based on interpretation of plan.
Procedural posture

Appellants, debtor and creditor, appealed the judgment of the United States District Court for the Western District of Wisconsin that affirmed a bankruptcy court's decision to award appellee Federal Communications Commission (FCC) post-confirmation interest for the period between confirmation of the debtor's 2000 plan of reorganization and commencement of new bankruptcy proceedings in 2006.

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Court :
Judge or Jurisdiction information not available
Commercial opinion summary, case decided on October 29, 2008 , LexisNexis #0109-057