Can a bankruptcy court order the “structured dismissal” of a Chapter 11 case if such dismissal would alter the ordinary priority rules for creditor distributions under the Bankruptcy Code? In Czyzewski v. Jevic Holding Corp., 580 U.S. (March 22, 2017) (Jevic), the Supreme Court recently determined that such an order cannot issue without consent from all affected creditors even in “rare cases in which courts could find sufficient reasons to disregard priority.”

Despite the Supreme Court’s recent decisions in Executive Benefits Insurance Agency v. Arkinson, 573 U.S. ___ (2014) (Arkinson) and Stern v. Marshall, 564 U. S. ___ (2011) (Stern),which dealt with the division of authority between bankruptcy courts and Article III courts, the question of whether a party could consent to a bankruptcy court’s final adjudication of so-called “Stern claims” remained an open issue. No longer. Recently, in Wellness International Network, Ltd. v. Sharif, ___ U.S.