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§ 362(b)(4)

In re Fernandez

Ruling
Emergency motion to enforce stay to prevent enforcement of environmental lien denied pursuant to police and regulatory powers exception.
Procedural posture

In a chapter 13 case, the debtor filed an emergency motion to enforce the automatic stay against a county, which sought to enforce a preliminary injunction requiring the debtor to cease a violation of environmental laws.

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Consumer opinion summary, case decided on February 26, 2010 , LexisNexis #0510-110

In re Qimonda AG

Ruling
Patent infringement action before the International Trade Commission was subject to stay once debtor's foreign insolvency proceeding was recognized.
Procedural posture

Patent owners brought an action before the International Trade Commission for patent infringement against a debtor in foreign insolvency proceedings, and a bankruptcy court entered an order recognizing the foreign proceedings. The Commission contended that the action before the Commission was excepted from the automatic bankruptcy stay under 11 U.S.C.S. § 362(b)(4).

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Commercial opinion summary, case decided on February 16, 2010 , LexisNexis #0410-109

DeSteph v. Connecticut Dept of Banking (In re DeSteph)

Ruling
State action to enforce securities laws fell within regulatory exception to automatic stay.
Procedural posture

Chapter 13 debtor filed an adversary proceeding against defendants, the State of Connecticut Department of Banking, the Commissioner, and a staff member (the State), for the State's alleged violation of the automatic stay under 11 U.S.C.S. § 362 and for violation of N.H. Rev. Stat. Ann. § 358-C. The State filed a motion to dismiss pursuant to Fed. R. Civ. P. 12(b)(6) and Fed. R. Bankr. P. 7012(b).

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Consumer opinion summary, case decided on December 02, 2009 , LexisNexis #0110-075

In re Fitness Mgmt. Group

Ruling
State enforcement of health club bond requirements against debtor was subject to police and regulatory power exception from stay.
Procedural posture

The State of North Carolina brought an action in a State court against a bankruptcy debtor alleging that the debtor committed unfair and deceptive trade practices by failing to maintain adequate bonds for its health clubs. The State moved for a declaration of exemption from the automatic stay under 11 U.S.C.S. § 362(b)(4) based on the State's exercise of its police and regulatory powers.

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Commercial opinion summary, case decided on November 23, 2009 , LexisNexis #1209-112

In re Spansion Inc.

Ruling
Stay applied to action by U.S. International Trade Commission under the Tariff Act of 1930.
Procedural posture

Debtors, chapter 11 debtors and a foreign debtor, moved to seek to enforce the automatic stay to prevent further action in a proceeding filed against them by a competitor under the Tariff Act of 1930, 19 U.S.C.S. § 1337, before the United States International Trade Commission (the ITC).

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Commercial opinion summary, case decided on October 01, 2009 , LexisNexis #1109-040

In re Pollock

Ruling
State enforcement of wage, hour and overtime law was covered by the police powers exception to stay.
Procedural posture

The debtor challenged an order issued by the New York Department of Labor (DOL) requiring the debtor to comply with wage, hour, and overtime law, asserting that the order violated the automatic stay provision of 11 U.S.C.S. § 362. The issue was whether the police and regulatory powers exception to the automatic stay provision under 11 U.S.C.S. § 362(b)(4) was applicable to the DOL's order.

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Consumer opinion summary, case decided on February 24, 2009 , LexisNexis #0609-039

In re Mystic Tank Lines Corp.

Ruling
Default judgment for environmental clean-up after debtor caused a gasoline leak was within police powers exception to stay.
Procedural posture

Appellant debtor, a gasoline shipper, challenged a judgment of the United States District Court for the District of New Jersey, affirming the bankruptcy court's allowance of a claim by appellee the State of New York based on damages for the clean-up of soil and groundwater contaminated with petroleum products caused by a leak at a gas station that was traced to a delivery of gasoline by the debtor.

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Court :
Judge or Jurisdiction information not available
Commercial opinion summary, case decided on October 16, 2008 , LexisNexis #1108-060

In re Aerobox Composite Structures LLC

Ruling
Proceeding before state human rights commission was an exercise of police and regulatory power and did not violate stay.
Procedural posture

The debtor's filed a motion to impose sanctions for violations of stay under 11 U.S.C.S. § 362 against the debtor's former employee for actions in connection with a proceeding before the Human Rights Commission (NM-HRC), which was part of the State of New Mexico Department of Labor, Human Rights Division. The employee had filed a discrimination complaint after she was terminated that resulted in a judgment against the debtor.

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Commercial opinion summary, case decided on April 10, 2008 , LexisNexis #0508-077

In re Iams Funeral Home Inc.

Ruling
Attorney general's action alleging violation of funeral laws was excepted from stay as exercise of police and regulatory power.
Procedural posture

A state attorney general sought entry of an order that declared all preneed funeral contracts held by a chapter 11 debtor to be excepted from property of the debtor's bankruptcy estate, and confirmed that the automatic stay, 11 U.S.C. § 362, did not apply to litigation initiated by the attorney general against the debtor for alleged violations of state law.

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Commercial opinion summary, case decided on December 06, 2007 , LexisNexis #1207-110

Trinity Meadows Raceway Inc. v. Texas Racing Commn (In re Trinity Meadows Raceway Inc.)

Ruling
State commission's revocation of debtor's racetrack license was an exercise of regulatory power and did not violate stay.
Procedural posture

Plaintiff debtor sued, asking that the court: (i) enjoin defendants, the Texas Racing Commission and the Former and Acting Chair of the Commission, from revoking, denying, or otherwise interfering with a license; (ii) enjoin defendants from continuing to refuse to reinstate the license; and/or (iii) hold that defendants were estopped to deny the effects of debtor's bankruptcy proceeding and automatic stay. Both sides sought summary judgment.

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opinion summary, case decided on September 11, 2007 , LexisNexis #1007-021