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ABI Journal

Rochellel's Daily Wire

July 11, 2022

Delaware Judge Approves ‘Uptier’ Financing that Involuntarily Subordinated Debt

Bankruptcy Judge Craig T. Goldblatt declined to interpret an indenture’s ratable treatment clause as anti-subordination in disguise.

3rd Circuit, Delaware

July 08, 2022

Second Circuit Bright-Line Rule: It’s Always a Stay Violation if Debtor Is a Defendant

Second Circuit exercises ‘hypothetical’ appellate jurisdiction when finality is murky.

2nd Circuit

July 07, 2022

May a Judge Revoke a Small Business Designation under Subchapter V of Chapter 11?

Bankruptcy Judge Gunn found the power to revoke a small business designation and proceed under ‘traditional’ chapter11 in lieu of dismissing or converting to chapter 7.

D.C. Circuit

July 06, 2022

Parties May Not Consent for Magistrate Judge to Decide a Bankruptcy Appeal

Fifth Circuit holds that 28 U.S.C. § 158 requires district judges or BAPs to decide bankruptcy appeals.

5th Circuit

July 05, 2022

District Judge Effectively Bars a Short Sale Without Paying the Homestead Exemption

Reversing, a Long Island district judge credits value to a homeowner’s ability to delay foreclosure, taking a position contrary to a recent decision from a Ninth Circuit B.A.P.

2nd Circuit, New York, New York Eastern District

July 01, 2022

Four Circuits Now Permit Fraudulent Transfer Attacks on Real Estate Tax Foreclosures

Circuit courts are split 4/3 on their interpretation of Supreme Court precedent holding that regularly conducted mortgage foreclosures are immune from fraudulent transfer attack.

2nd Circuit

June 30, 2022

Chapter 13 Creditors Get Exempt Assets that Produce Income

Exempt assets are included in the calculation of chapter 13 projected disposable income to the extent that the exempt asset produces income.

2nd Circuit, New York, New York Northern District

June 29, 2022

Lender Defaulted on the Merits for ‘Prolonged, Extraordinary’ Discovery Violations

Despite contrary Second Circuit dicta, retiring Judge Robert Drain certified a nationwide class in a suit for violation of the discharge injunction.

2nd Circuit, New York, New York Southern District

June 28, 2022

Supreme Court to Decide Whether Section 363(m) Is a Jurisdictional Bar to Appeal

The Supreme Court now has two bankruptcy cases on the calendar for argument in the term to begin in October.

Supreme Court

June 27, 2022

A Deceased Chapter 13 Debtor Can Still Obtain a Discharge, Judge Parker Says

Death is a reason for waiving the requirement for completing a financial management course.

5th Circuit, Texas, Texas Western District