March 2024
Baltimore district judge applies the Fourth Circuit’s ‘substantial and unanticipated’ test to modifications of chapter 11 plans.
Chicago Bankruptcy Judge David Cleary followed a decision by then-district Judge David Hamilton and “respectfully” disagreed with decisions by two predecessors on the same bankruptcy bench.
In the Fourth Circuit, creditors are compensated when there is a ‘substantial improvement’ in a chapter 13 debtor’s financial condition.
Jan 2024