Second, Fifth, Ninth and Eleventh Circuits agree that supplying “necessaries” by itself won’t justify a maritime lien.

Ninth Circuit is hesitant to make bankruptcy time deadlines jurisdictional.

The Ninth Circuit quickly rectifies its own mistake by allowing creditors to recover counsel fees in suits to recover damages for automatic stay violations.

Corporate debtors anticipating disputes with secured lenders have a good reason for filing chapter 11 in California, assuming there is no need for an injunction barring suit against a
non-bankrupt third party.