The court noted that the DOJ might prosecute cannabis-related businesses under the CSA, notwithstanding plan confirmation. Thus, Garvin may have foreclosed any future DOJ CSA-based noneconomic objections to cannabis reorganizations.

Yesterday, Lehman Brothers Holdings Inc. (LBHI) and the Official Committee of Unsecured Creditors of LBHI (the Committee) filed a complaint against JPMorgan Chase Bank, N.A. (JPMorgan) in the U.S. Bankruptcy Court for the Southern District of New York.