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ABI Journal

Rochellel's Daily Wire

August 30, 2023

First Circuit Describes How to Value an Interest in Entireties Property

The value of a debtor’s interest in entireties property isn’t necessarily 50% of the value of the entire property.

1st Circuit

August 29, 2023

Eleventh Circuit Narrowly Reads a State Fee-Shifting Statute

The lawsuit was under federal law, not state law, even though Section 544(b)(1) incorporated state fraudulent transfer law.

11th Circuit

August 28, 2023

Four Circuits Agree: Debtors Get Refunds for Overpayment of U.S. Trustee Fees

With four circuits in agreement, the Supreme Court isn’t likely to grant cert to rule on whether chapter 11 debtors are entitled to refunds for overpayment of U.S. Trustees fees that were held unconstitutional in Siegel.

9th Circuit

August 25, 2023

Eighth Circuit Definitively Holds: Avoidance Actions Are Estate Property and Can Be Sold

Now a circuit judge, a former bankruptcy judge makes quick work of a troublesome issue about property of the estate.

8th Circuit

August 24, 2023

State Court Is the ‘More Appropriate Forum’ to Divide Marital Property

The bankruptcy court can divide marital property, but just because it can doesn’t mean it should, Judge Thuma says.

10th Circuit, New Mexico

August 23, 2023

Fourth Circuit: State Law Claims for Discharge Violations Are Not Preempted

The Fourth Circuit declined to follow the First and Sixth Circuits on preemption of automatic stay violations by expanding the ban to redress for discharge violations.

4th Circuit

August 22, 2023

Three Circuits Agree: The ACA’s ‘Penalty’ Is Actually a Tax Entitled to Priority

Looking beyond the label assigned by the Affordable Care Act, three circuits have now held that failure to pay the ‘individual mandate’ for purchasing health insurance gave rise to a tax entitled to priority in bankruptcy.

6th Circuit

August 21, 2023

Government Bar Date Applies to DOE Loans Even When the Servicer Is Private

As long as the student loan is owing to the government, the Fifth Circuit holds that the government bar date applies even when the servicer is a private company.

5th Circuit

August 18, 2023

State Law Requiring Exhaustion of Administrative Remedies Won’t Divest Jurisdiction

Neither a contract nor state law requiring exhaustion of administrative remedies can divest the bankruptcy court of ‘core’ jurisdiction, even after plan confirmation.

D.C. Circuit

August 17, 2023

Fifth Circuit Adheres to ‘Person Aggrieved’ for Appellate Standing in Bankruptcy

Bankruptcy courts can have subject matter jurisdiction to approve settlements between nondebtors.

5th Circuit