Baltimore district judge applies the Fourth Circuit’s ‘substantial and unanticipated’ test to modifications of chapter 11 plans.
Oct 2023
Eighth Circuit BAP ‘at a minimum’ requires substantial changes in financial condition for a debtor to modify a confirmed chapter 12 plan.
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.
