Practice and Procedure

Supreme Court Jun 15, 2023

Supreme Court: The Bankruptcy Code Waived Tribes’ Sovereign Immunity

The Supreme Court resolved a split of circuits in an opinion that could give support to the notion that arbitration agreements are not enforceable in bankruptcy.

The Consumer Bankruptcy Reform Act: The Uncoupling of Debts

The Consumer Bankruptcy Reform Act: The Uncoupling of Debts By Brittany M. Woodman The Consumer Bankruptcy Reform Act (CBRA), originally introduced in December 2020, was reintroduced in September 2022 by Sen. Elizabeth Warren (D-Mass.) and Rep. Jerrold Nadler (D-N.Y.)

7th Circuit Apr 27, 2023

‘Preponderance’ Replaced ‘Clear and Convincing’ on Adoption of the Bankruptcy Code

The Seventh Circuit explained how preponderance of the evidence became the standard of proof for turnovers and dischargeability when the Bankruptcy Code replaced the Bankruptcy Act.
Supreme Court Apr 25, 2023

Supreme Court Hears Oral Argument on Tribal Sovereign Immunity

It appears as though the Supreme Court will decide Lac du Flambeau based entirely on textual analysis of Section 106(a), which does not explicitly abrogate sovereign immunity as to Native American tribes.

Notification of Bankruptcy Requires Lifting Garnishment of Post-Petition Income

Although the automatic stay does not require turning over property garnished before bankruptcy, a creditor may not continue garnishing property after filing, Judge Burgess says.

Core vs. Non-Core Doesn’t Determine Whether Arbitration Will Be Enforced

Chicago’s Judge Cleary didn’t compel arbitration of an affirmative counterclaim by the debtor against the creditor that would be determined in the course of passing on the allowance of the creditor’s proof of claim.

Judge Klein Charts the Path for Discharging Student Loans and Not Being Reversed

Bankruptcy Judge Christopher Klein provides authority for student loan debtors who win in bankruptcy court but face an appeal aimed at the trial court’s fact-findings.
6th Circuit Mar 28, 2023

‘Person Aggrieved’ for Appellate Standing Test May Have Died, but May Be Resurrected

Sixth Circuit judges wrote 17 pages of dicta to muse on whether the ‘person aggrieved’ test for appellate standing died with the adoption of the Bankruptcy Code but remains good law under the ‘zone-of-interests’ test.
9th Circuit Mar 22, 2023

Ninth Circuit BAP Rules on a Question to Be Decided Soon by the Supreme Court

Like the question in MOAC to be decided soon by the Supreme Court, the BAP says that the qualifications for an involuntary petitioner are not jurisdictional and can be waived.