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§ 303(i)

Miller v. Adell (In re John Richards Homes Bldg. Co. LLC)

Ruling
Bankruptcy court erred in denying award of debtor's attorneys' fees following dismissal of involuntary cases.
Procedural posture

Appellant law firm sought attorney fees and costs incurred after appellee's involuntary bankruptcy petition against appellant debtor was dismissed. The law firm and debtor appealed the Bankruptcy Court for the Eastern District of Michigan's order that denied the application for lack of authority. A magistrate recommended that the order be reversed and that appellee's motion for partial dismissal be denied. Appellee timely objected.

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Commercial opinion summary, case decided on March 30, 2009 , LexisNexis #0509-025

John Richards Homes Bldg. Co. LLC v. Adell (In re John Richards Homes Bldg. Co. LLC)

Ruling
Appeal of denial of additional damages for debtor's filing involuntary petition against creditor in bad faith was not barred by res judicata after similar proceeding in another district court was dismissed.
Procedural posture

Appellee, a judgment debtor, moved for partial dismissal of appellant judgment creditor's challenge to an order of the United States Bankruptcy Court for the Eastern District of Michigan that denied the creditor's request for additional punitive damages based on the judgment debtor's post-award conduct. The judgment debtor argued that res judicata or collateral estoppel in a Florida case between the parties precluded the appeal.

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Commercial opinion summary, case decided on March 12, 2009 , LexisNexis #0909-063

In re Bicoastal Holding Co.

Ruling
Involuntary petition dismissed as filed in bad faith against shell corporation with no assets.
Procedural posture

Creditor filed an involuntary bankruptcy case against a debtor holding company. The debtor moved to dismiss the involuntary chapter 7 petition as filed in bad faith and for costs, attorneys' fees, damages, and punitive damages.

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Commercial opinion summary, case decided on March 11, 2009 , LexisNexis #0509-072

Sofris v. Maple-Whitworth Inc. (In re Maple-Whitworth Inc.)

Ruling
Award of attorneys' fees to involuntary debtor in dismissed case could be assessed against fewer than all petitioning creditors.
Procedural posture

After dismissing an involuntary bankruptcy petition, the bankruptcy court awarded the purported debtor $ 42,257 in attorneys' fees and costs pursuant to 11 U.S.C.S. § 303(i)(1). The bankruptcy court failed to rule on a challenge to the award based on a waiver theory. A divided Ninth Circuit Bankruptcy Appellate Panel (BAP) affirmed the award to fewer than all petitioners. Appellant petitioner appealed.

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Court :
Judge or Jurisdiction information not available
Commercial opinion summary, case decided on February 10, 2009 , LexisNexis #0309-095

In re Analytica Wire Inc.

Ruling
Debtor not entitled to attorneys' fees and costs in involuntary case that was dismissed pursuant to agreement.
Procedural posture

Respondent debtor filed an application for attorney's fees and costs under 11 U.S.C.S. § 303(i) that it incurred while defending petitioner creditor's involuntary bankruptcy petition.

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Commercial opinion summary, case decided on September 04, 2008 , LexisNexis #0908-108

In re Synergistic Techs. Inc.

Ruling
Attorneys'fees awarded to debtor in involuntary case where petitioner was not holder of an undisputed unsecured claim.
Procedural posture

The debtor, by and through its remaining director, moved for judgment, pursuant to 11 U.S.C. § 303(i), against the petitioner who filed the involuntary petition, for attorney's fees, costs, and actual and punitive damages. The petitioner and the director were both shareholders of the debtor, and were embroiled in litigation and an arbitration proceeding prior to the filing of the involuntary petition.

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opinion summary, case decided on August 06, 2007 , LexisNexis #0907-073

In re VII Holdings Co.

Ruling
Standing to seek to recover attorneys'fees is limited to debtors
Procedural posture

Petitioner filed an involuntary petition against debtor. Debtor owned an interest in certain real property which had been in foreclosure proceedings. The involuntary case triggered the automatic stay, frustrating the foreclosure process. Creditors, a mortgage holder and the buyer of the foreclosed property, argued the involuntary petition was filed in bad faith. The court agreed and dismissed the petition. Creditors sought attorneys'fees.

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opinion summary, case decided on February 22, 2007 , LexisNexis #0307-108

In re John Richards Homes Bldg. Co.. L.L.C.

Ruling
Judgment that a creditor had filed an involuntary petition in bad faith and an award of damages for costs, attorneys'fees, compensatory damages, and punitive damages was affirmed.
Procedural posture

Plaintiff petitioning creditor sought review of a judgment of the District Court for the Eastern District of Michigan that upheld a judgment of a bankruptcy court that the creditor had filed an involuntary petition in bad faith and awarded damages defendant alleged of debtor costs, attorneys'fees, compensatory damages, and punitive damages pursuant to 11 U.S.C. § 303(i).

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Court :
Judge or Jurisdiction information not available
opinion summary, case decided on March 01, 2006 , LexisNexis #0306-078