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ABI Journal

Rochellel's Daily Wire

January 12, 2024

Lender’s Attorneys Paid Twice the Debtor’s Counsel Fees

Unnecessarily holding the lender’s feet to the fire resulted in the allowance of attorneys’ fees to the lender that were twice the debtor’s counsel fees.

5th Circuit, Texas, Texas Western District

January 11, 2024

For ‘Sub V’ Eligibility, Count the Debt of Affiliates Liquidating in Chapter 7

Bankruptcy court disregards SEC regulations defining ‘voting securities’ in deciding whether a Subchapter V debtor has ‘affiliates’ in bankruptcy.

11th Circuit, Georgia, Georgia Northern District

January 10, 2024

Equity Governs When Lease Rejection May Be Retroactive to the Filing Date

The ‘cap’ for lease-rejection damages can start when the debtor attempts to surrender the premises.

2nd Circuit, New York, New York Southern District

January 09, 2024

Denial of Modification of a Chapter 11 Plan Is Final and Appealable

Baltimore district judge applies the Fourth Circuit’s ‘substantial and unanticipated’ test to modifications of chapter 11 plans.

4th Circuit, Maryland

January 08, 2024

How to Turn Prepetition Work into a Postpetition Administrative Claim

Prepetition brokerage fees characterized as rent under an aircraft lease were administrative claims to be paid in full under Section 365(d)(5).

2nd Circuit, New York, New York Southern District

January 05, 2024

U.S. Trustee Dodged Payment of Attorneys’ Fees Under the Equal Access to Justice Act

The Sixth Circuit holds that a debtor cannot recover attorneys’ fees from the U.S. Trustee under the EAJA in a contested matter, but leaves open the possibility of liability for counsel fees in a losing adversary proceeding.

6th Circuit

January 04, 2024

With Reservations, a Chapter 11 Debtor with No Financial Distress Avoids Dismissal

Bankruptcy Judge Whitley says that a no-opt-out plan for a solvent debtor might violate creditors’ due process and jury trial rights.

4th Circuit, North Carolina, North Carolina Western District

January 03, 2024

U.S. Trustee Rebuffed in Objecting to Rates Higher than Local Rates

‘National’ rates higher than ‘local’ rates can be locked in by retention orders under Section 328(a).

5th Circuit, Mississippi, Mississippi Northern District

January 02, 2024

BAP Lays Down Pleading Rules for Fee Applications in Small Chapter 7 Cases

The fee application by an attorney for a chapter 7 trustee in a small case must state facts to show why the services must have been performed by an attorney, not by the trustee.

9th Circuit

December 28, 2023

When Inherited Property Becomes Property of the Debtor’s Bankruptcy Estate

Being an heir by itself doesn’t bring a decedent’s estate into the heir’s bankruptcy estate.

7th Circuit, Wisconsin, Wisconsin Eastern District