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Circuit Court

Mission Hen, LLC v. Lee

Ruling
Claim that matured during the plan’s term was subject to modification and could be bifurcated. (9th Cir.)
Issue(s)
Contents of Plan.

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Commercial opinion summary, case decided on May 22, 2025 , LexisNexis #0725-097

Adair, In re--Adair v. Stutsman Constr., L.L.C.

Ruling
Unclean hands defense to nondischargeability was improperly precluded as it was not litigated in state court default judgment proceeding. (5th Cir.)
Issue(s)
Exceptions to Discharge; Types of Debt Excepted; Willful and Malicious Injury to Another Entity or Property of Another Entity.

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Consumer opinion summary, case decided on May 20, 2025 , LexisNexis #0725-089

BSA, In re

Ruling
Confirmed Chapter 11 plan including nonconsensual third party releases could not be vacated due to effect on completed insurance buyback funding the plan. (3d Cir.)
Issue(s)
Confirmation of Plan; Requirements; Plan Proposed in Good Faith.

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Commercial opinion summary, case decided on May 13, 2025 , LexisNexis #0725-069

Ellingsworth Residential Cmty. Ass'n, Inc., In re--Guan v. Ellingsworth Residential Cmty. Ass'n, Inc.

Ruling
Not-for-profit homeowners association was an eligible Subchapter V debtor as eligibility is not limited to for-profit entities. (11th Cir.)
Issue(s)
Definitions; “Small Business Debtor”.

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Commercial opinion summary, case decided on January 13, 2025 , LexisNexis #0325-051

Serta Simmons Bedding, L.L.C., In re--Excluded Lenders v. Serta Simmons Bedding, L.L.C.

Ruling
Court rejected plan due to indemnity offered to “superpriority” holders, whose claims had been individually negotiated, resulting in unequal treatment of claims within the class. (5th Cir.)
Issue(s)
Contents of Plan; Discretionary Provisions; Claims of Debtor; Settlement or Adjustment.

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Commercial opinion summary, case decided on December 31, 2024 , LexisNexis #0325-013

Clem, In re-- Clem v. Tomlinson

Ruling
Bankruptcy court erred in failing to apply collateral estoppel to arbitrator’s findings that debtor’s alleged fraud and misrepresentation were not established. (5th Cir.)
Issue(s)
Exceptions to Discharge; Types of Debt Excepted; Fraud; False Pretenses, False Representations or Actual Fraud.

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Consumer opinion summary, case decided on December 23, 2024 , LexisNexis #0325-005

Financial Oversight & Mgmt. Bd. for P.R., In re

Ruling
Bondholders’ lien on Puerto Rico Electric Power Authority's special revenues was subordinate to the utility’s reasonable and necessary post-petition operating expenses. (1st Cir.)
Issue(s)
Post Petition Effect of Security Interest; Liens on Special Revenues.

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Court :
Commercial opinion summary, case decided on November 13, 2024 , LexisNexis #0125-065

Hertz Corp., In re--Wells Fargo Bank, N.A. v. Hertz Corp.

Ruling
Bankruptcy court correctly disallowed claim for unmatured interest as it was either definitionally interest or its economic equivalent. (3d Cir.)
Issue(s)
Allowance of Claims or Interests; Disallowance; Unmatured Interest.

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Court :
Commercial opinion summary, case decided on September 10, 2024 , LexisNexis #0125-054

Generation Res. Holding Co., LLC, In re--Rajala v. Spencer Fane LLP

Ruling
Trustee could not recover legal fees where law firms were neither initial nor subsequent transferees as they never received the transferred property. (10th Cir.)
Issue(s)
Liability of Transferee of Avoided Transfer.

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Court :
Commercial opinion summary, case decided on July 10, 2020 , LexisNexis #0820-066

Belton, In re--Belton v. GE Capital Retail Bank

Ruling
Proceeding for violation of the discharge order was not an arbitrable dispute. (2d Cir.)
Issue(s)
Effect of Discharge; Avoidance And Injunctive Relief; Injunction Against Actions to Recover a Debt as Personal Liability of Debtor.

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Court :
Consumer opinion summary, case decided on June 16, 2020 , LexisNexis #0720-087