Bankruptcy Judge Paul Bonapfel differed with two judges in Houston by holding that a nonaccepting class in Subchapter V means that a plan must be confirmed in cramdown.
Bankruptcy Judges Wiles in New York decided that insiders were not entitled to releases under Section 503(c), but not for the reasons contained in Purdue.
Disagreeing with two bankruptcy courts in Houston, Miami’s Judge Isicoff holds that a Sub V plan with a nonvoting class can be confirmed only as a nonconsensual plan.