Skip to main content

§ 1334(c)

Best Ins. Servs. Inc. v. Wells (In re Wells)

Ruling
Bankruptcy court abstained from state law liability determination.
Procedural posture

Plaintiff creditor filed an adversary proceeding against defendant debtor seeking a determination that its debt was nondischargeable. The debt was unliquidated and was the subject of a pending state court proceeding. The debtor filed a counterclaim which was essentially the same as that filed in the state court action. The creditor requested that the court abstain from hearing the counterclaim on the basis that it was founded solely on state law.

ABI Membership is required to access the full summary of Best Ins. Servs. Inc. v. Wells (In re Wells) Please sign in if you are already an ABI member, or otherwise you may Become an ABI Member

Consumer opinion summary, case decided on January 30, 2009 , LexisNexis #0309-092

In re Radetic

Ruling
Bankruptcy court voluntarily abstained from hearing contract dispute related to debtor's bankruptcy.
Procedural posture

Creditor filed a motion for relief from the automatic stay to proceed against the debtor in a state court action filed prepetition. The action arose from a failed real estate contract. The creditor, as listing agent, sought a commission from the debtor. The stay motion in effect called on the bankruptcy court to abstain from determining the breach of contract dispute.

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

Consumer opinion summary, case decided on January 16, 2009 , LexisNexis #0309-024

Joremi Enters. v. Hershkowitz (In re New 118th LLC)

Ruling
Guarantee dispute remanded pursuant to mandatory abstention once established that the matter would not affect administration.
Procedural posture

Plaintiff investors brought an action in state court against defendants: debtor, three individuals, et al. After that court ordered relief against the affiliated debtors, plaintiffs removed the action to district court which referred it to the instant court. Plaintiffs assigned the proceeds of their claims to debtors'estates, and filed an amended complaint, which dropped all defendants other than the individuals, one of which moved to remand.

ABI Membership is required to access the full summary of Joremi Enters. v. Hershkowitz (In re New 118th 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 November 13, 2008 , LexisNexis #1208-091

Schwab v. Beneficial Consumer Discount Co. (In re Bowler)

Ruling
Bankruptcy court abstained from hearing trustee's claims regarding secured status of creditor's claim and alleged violations of Truth in Lending Act.
Procedural posture

Defendant lender filed a motion to dismiss plaintiff trustee's adversary complaint to determine that the creditor did not have a secured interest in the debtors'property subject to a mortgage and for damages under the Truth in Lending Act (TILA).

ABI Membership is required to access the full summary of Schwab v. Beneficial Consumer Discount Co. (In re Bowler) Please sign in if you are already an ABI member, or otherwise you may Become an ABI Member

Consumer opinion summary, case decided on October 14, 2008 , LexisNexis #0109-027

Smith v. McLeskey (In re Bay Vista of Va. Inc.)

Ruling
Bankruptcy court declined to abstain from proceeding for turnover of excess funds received by creditor in foreclosure of debtor's property.
Procedural posture

Defendants, creditors of a chapter 7 debtor, moved pursuant to 28 U.S.C.S. § 1334 for abstention of the complaint filed by plaintiff chapter 7 trustee, which sought a turnover pursuant to 11 U.S.C.S. § 542 of excess funds collected by the creditors on certain notes, alleged a breach of contract, and alleged that the creditors were judicially estopped from collecting an amount in excess of what they represented to a state court was owed them.

ABI Membership is required to access the full summary of Smith v. McLeskey (In re Bay Vista of Va. 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 September 24, 2008 , LexisNexis #1108-019

Estate of Smith v. Columbia Prop. Group

Ruling
Discretionary abstention appropriate for medical malpractice case in which a co-defendant had filed for bankruptcy.
Procedural posture

Plaintiff estate filed the instant wrongful death, medical malpractice action in a state court. One of the defendants removed the action to federal court. The matter was before the court upon the estate's motion for abstention and remand.

ABI Membership is required to access the full summary of Estate of Smith v. Columbia Prop. Group 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 22, 2008 , LexisNexis #1108-057

White Oak Corp. v. American Intl Group Inc. (In re National Eastern Corp.)

Ruling
Proceeding against debtor contractor's sureties and attorneys for acting in self-interest under indemnity agreement remanded to state court.
Procedural posture

One plaintiff and one defendant (objecting parties) filed motions to abstain and to remand to state court the captioned adversary proceeding, which had been removed to the bankruptcy court pursuant to 28 U.S.C.S. § 1452(a). The basis of the complaint was that defendants, sureties and attorneys, rather than acting on the behalf of the plaintiffs, the debtor and its affiliates under an indemnity agreement, acted in their own self-interest.

ABI Membership is required to access the full summary of White Oak Corp. v. American Intl Group Inc. (In re National Eastern Corp.) Please sign in if you are already an ABI member, or otherwise you may Become an ABI Member

Commercial opinion summary, case decided on July 25, 2008 , LexisNexis #0808-088

Anderson v. Cain

Ruling
State law case that would determine value of 97 percent of claims against the estate remanded.
Procedural posture

Plaintiffs filed an action against defendants in state court alleging that defendants conspired to misappropriate funds that were intended for the sale of plaintiffs' property and that as a result of defendants' conduct the sale did not go forward and plaintiffs lost the benefit of the sale. Defendant debtors removed the matter to the court, and plaintiffs filed a motion for abstention or to remand the matter to state court.

ABI Membership is required to access the full summary of Anderson v. Cain Please sign in if you are already an ABI member, or otherwise you may Become an ABI Member

Consumer opinion summary, case decided on July 24, 2008 , LexisNexis #0808-086

Strong v. Western United Life Assurance Co. (In re Tri-Valley Distrib.)

Ruling
Order that did not fully resolve adversary proceeding was not a final appealable order.
Procedural posture

Plaintiff debtors and unsecured creditors sued defendant company, alleging, inter alia, fraudulent transfer and negligent lending stemming from a loan to a creditor. The United States Bankruptcy Appellate Panel for the Tenth Circuit affirmed a bankruptcy court's order denying the company's motion to dismiss as to claims related to a transferred property, but dismissing all other claims. The parties cross-appealed and moved to dismiss the appeals.

ABI Membership is required to access the full summary of Strong v. Western United Life Assurance Co. (In re Tri-Valley Distrib.) 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 July 15, 2008 , LexisNexis #0808-069

Booker v. Booker

Ruling
Bankruptcy court abstained from dispute between debtor and creditor where debtor's case had been dismissed.
Procedural posture

Plaintiffs, creditors, filed an adversary proceeding against defendant debtor seeking a determination that their debts were nondischargeable pursuant to 11 U.S.C.S. § 523(a)(4) and § 523(a)(6). The creditors also alleged claims under state law. The creditors moved for summary judgment.

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

Consumer opinion summary, case decided on June 23, 2008 , LexisNexis #0808-087