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ABI Journal

Rochellel's Daily Wire

January 19, 2023

Dubious Eleventh Circuit Opinion Permits Collateral Attack on Final Confirmation Order

Although the chapter 13 confirmation order was concededly final and enforceable, the appeals court set aside a plan provision modifying a residential mortgage.

11th Circuit

January 18, 2023

Supreme Court to Hear Two More Bankruptcy Cases This Term

The high court will decide whether a real estate tax foreclosure can violate the Takings Clause and whether Section 106 abrogates sovereign immunity as to Native American tribes.

Supreme Court

January 17, 2023

Second Circuit Limits the Significance of Homaidan on Discharge of Private Student Loans

The Fair Credit Reporting Act doesn’t require credit reporting agencies to resolve disputed facts or law about the discharge of private student loans.

2nd Circuit

January 13, 2023

Burford Abstention Can Apply in Bankruptcy Alongside Abstention in 28 U.S.C. § 1334(c)

Interference with state regulators can compel a bankruptcy court to abstain, even if abstention was not required under 28 U.S.C. § 1334(c).

5th Circuit

January 12, 2023

Bankruptcy Courts Disagree on Paying U.S. Trustee Fees by Liquidating Trusts

Adroitly drafting a chapter 11 plan may avoid having a liquidating trust pay quarterly fees to the U.S. Trustee.

4th Circuit, Virginia, Virginia Eastern District

January 11, 2023

Adverse Plan Amendment Requires a Disclosure Statement and More Voting, Circuit Says

The Eleventh Circuit stated the obvious: A class that gets something under a chapter 11 plan is entitled to a disclosure statement and to vote again if an amendment takes it away, even if the class was entitled to nothing in the first place.

11th Circuit

January 10, 2023

Crypto Customers Don’t Own Their Deposits with Celsius Network, Judge Glenn Says

Applying ordinary contract law, New York judge rules that customers are bound by contracts they haven’t read.

2nd Circuit, New York, New York Southern District

January 09, 2023

The Best Opinion Yet Ordering Refunds for Overpayment of U.S. Trustee Fees

All three courts to confront the question have now ordered the government to refund overpayments of U.S. Trustee fees.

4th Circuit, Virginia, Virginia Eastern District

January 06, 2023

Ninth Circuit Says: A Sale Order Can’t Alter the Terms of the Contract

A surprising opinion by the Ninth Circuit was nonprecedential.

9th Circuit

January 05, 2023

Deferred Settlement Agreements Aren’t Executory Contracts and Can’t Be Assumed

A deferred settlement agreement, like a workout agreement, can’t be assumed under Section 365.

9th Circuit, California, California Eastern District