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The Seventh Circuit Court of Appeals recently handed down a decision with significant implications for landlords contemplating lease termination agreements with distressed tenants. Ruling on a direct appeal in the chapter 11 case In re Great Lakes Quick Lube LP, the court held that a lease termination agreement between a landlord and a financially distressed tenant can be voided as either a fraudulent conveyance or a preferential transfer in the tenant’s subsequent bankruptcy case. 

The Supreme Court’s decision last term in Baker Botts v. Asarco, in which the Court ruled that professionals that are paid from a debtor’s bankruptcy estate cannot be compensated for time spent defending their fee applications, continues to rankle bankruptcy practitioners.  Moreover, a recent decision in a Delaware bankruptcy case shows that the impact of Asarco will not be easily circumvented.

Key Point

The court adjourned a bankruptcy hearing on the basis that a Spanish court sanctioned liquidation plan for a group of companies in which the debtor had an interest might release value for creditors.

The Facts

Key Points

  • Receivers only owe a duty of care to those parties who hold an interest in the equity of redemption.
  • Upon the making of a bankruptcy order, the bankrupt ceases to participate in any such interest and the equity of redemption vests in the trustee in bankruptcy.

The Facts

At a hearing in late August, Judge Robert Gerber expressed his annoyance with both sides in the ongoing battle to determine whether General Motors LLC (“New GM”), the entity formed in 2009 to acquire the assets of General Motors Corporation (“Old GM”), is shielded from lawsuits based on ignition switch defects in cars manufactured prior to New GM’s acquisition of the assets of Old GM in 2009.

Key Point

Judgment sets out the rationale behind validating three payments made by a Company after the presentation of a winding up petition.

The Facts

This was the third application made by Sahaviriya Steel Industries UK Limited (the “Company”) in connection with payments made that would require validation under s127 Insolvency Act 1986. The payments were necessary to keep part of its business going pending discussions on sale or restructuring.

The Decision

Key Point

Judgement provides detailed guidance on administrators making distributions in relation to EU incorporated companies.

The Facts

Energy Future Holdings (“EFH” or “Debtors”) has cleared all of the preliminary hurdles in its path as it moves towards the confirmation of its plan of reorganization (the “Plan”).