Skip to main content

§ 503(b)(9)

In re ADI Liquidation Inc.

Ruling
Debtors could use setoff rights to reduce amount of goods priority claim.
Issue(s)
Could debtor use offset rights to reduce the amount of a § 503(b)(9) goods priority claim?

ABI Membership is required to access the full summary of In re ADI Liquidation Inc. Please sign in if you are already an ABI member, or otherwise you may Become an ABI Member

Commercial opinion summary, case decided on May 05, 2015 , LexisNexis #0615-010

Puerto Rico Elec. Power Auth. v. Rentas (In re PMC Mktg. Corp.)

Ruling
Bankruptcy court erred in applying improper analysis of whether electricity supplied to debtor within 20 days of petition date was a "service" rather than a "good."
Issue(s)
Whether the bankruptcy court erred in concluding that the electricity a utility supplied to the debtor within the twenty days of the petition date was a "service" rather than a "good" entitled to receive priority treatment as an administrative expense under 11 U.S.C.S. § 503(b)(9).

ABI Membership is required to access the full summary of Puerto Rico Elec. Power Auth. v. Rentas (In re PMC Mktg. Corp.) Please sign in if you are already an ABI member, or otherwise you may Become an ABI Member

Court :
Judge or Jurisdiction information not available
Commercial opinion summary, case decided on September 23, 2014 , LexisNexis #1014-084

In re World Imps.

Ruling
Claims for shipments made directly to debtor's customers were not entitled to administrative expense status.
Issue(s)
Were claims based on shipments made directly to debtor's customers entitled to administrative expense status?

ABI Membership is required to access the full summary of In re World Imps. Please sign in if you are already an ABI member, or otherwise you may Become an ABI Member

Commercial opinion summary, case decided on September 10, 2014 , LexisNexis #1014-010

In re NE OPCO Inc.

Ruling
Utility's administrative expense claim for electricity denied as not for a "good" while claim for natural gas, which was a "good," was allowed.
Issue(s)
Was utility entitled to administrative expense claim for the electricity and natural gas it provided to the debtors in the 20-days prior to bankruptcy.

ABI Membership is required to access the full summary of In re NE OPCO Inc. Please sign in if you are already an ABI member, or otherwise you may Become an ABI Member

Commercial opinion summary, case decided on November 01, 2013 , LexisNexis #1213-011

In re Wezbra Dairy LLC

Ruling
Creditor denied administrative expense for cost of silage received by debtor within 20 days of petition date.
Procedural posture

Sellers of silage to a bankruptcy debtor for use in the debtor's dairy operation sought to recover the cost of silage received by the debtor during the 20 days prior to the debtor's bankruptcy petition pursuant to 11 U.S.C.S. § 503(b)(9) as the cost of goods received by the debtor in the ordinary course of business. The sellers moved for payment of the administrative expenses and a creditor objected.

ABI Membership is required to access the full summary of In re Wezbra Dairy LLC Please sign in if you are already an ABI member, or otherwise you may Become an ABI Member

Commercial opinion summary, case decided on June 03, 2013 , LexisNexis #0713-115

In re Energy Conversion Devices Inc.

Ruling
Administrative expense claim for steel delivered to debtor prior to petition date allowed in full.
Procedural posture

In these jointly-administered chapter 11 cases, a creditor filed a motion seeking an order allowing its 11 U.S.C.S. § 503(b)(9) administrative expense and compelling the liquidation trustee to pay it immediately. The liquidation trustee under the chapter 11 debtors' confirmed plan filed an objection.

ABI Membership is required to access the full summary of In re Energy Conversion Devices Inc. Please sign in if you are already an ABI member, or otherwise you may Become an ABI Member

Commercial opinion summary, case decided on February 11, 2013 , LexisNexis #0313-009

In re Richfield Equities, LLC

Ruling
Conversion of case from chapter 11 to chapter 7 did not reset date for filing an administrativeexpense claim. (Bankr. E.D. Mich.)
Issue(s)
Could creditor file an administrative expense claim after expiration of the original deadline where the case had subsequently been converted to chapter 7?

ABI Membership is required to access the full summary of In re Richfield Equities, LLC Please sign in if you are already an ABI member, or otherwise you may Become an ABI Member

Commercial opinion summary, case decided on January 15, 2013 , LexisNexis #0916-117

In re Momenta Inc.

Ruling
Creditor vendor was not entitled to administrative expense claim for drop shipment transactions.
Procedural posture

A vendor of Chapter 11 debtor filed a motion for the allowance of an administrative expense claim of $163,527.95 pursuant to 11 U.S.C.S. § 503(b)(9).

ABI Membership is required to access the full summary of In re Momenta Inc. Please sign in if you are already an ABI member, or otherwise you may Become an ABI Member

Commercial opinion summary, case decided on August 19, 2011 , LexisNexis #0911-040

In re Grede Foundries Inc.

Ruling
Utilities' claim for value of electricity supplied in 90 days prior to petition date allowed.
Procedural posture

Two utilities filed claims for administrative expenses under 11 U.S.C.S. § 503(b)(9) for the value of electricity supplied to debtor in the 90 days pre-petition. Debtor objected. The utilities moved to strike a reply brief.

ABI Membership is required to access the full summary of In re Grede Foundries Inc. Please sign in if you are already an ABI member, or otherwise you may Become an ABI Member

Commercial opinion summary, case decided on June 01, 2010 , LexisNexis #0910-012

In re Circuit City Stores Inc.

Ruling
Administrative expense claim for goods provided to debtor 20 days prior to petition date temporarily disallowed pending determination of avoidability.
Procedural posture

Claimants submitted requests for administrative expenses under 11 U.S.C.S. § 503(b)(9) for providing goods to bankruptcy debtors within 20 days prior to the bankruptcy petition date. The debtors moved for temporary disallowance of the claims under 11 U.S.C.S. § 502(d) pending a determination of whether the claimed expenses constituted avoidable preferential transfers.

ABI Membership is required to access the full summary of In re Circuit City Stores Inc. Please sign in if you are already an ABI member, or otherwise you may Become an ABI Member

Commercial opinion summary, case decided on January 06, 2010 , LexisNexis #0210-078