A little over a year ago, I authored an article addressing the question of whether the “Absolute Priority Rule” applied to Chapter 11 bankruptcy cases filed by an individual. That article, which focused on the decision of the Fourth Circuit Court of Appeals in In re Maharaj 681 F. 3d 558 (4th Cir. 2012), noted that the trend appeared to be towards the conclusion that the Absolute Priority Rule did apply in such cases—but that in Michigan, the issue had not yet been addressed by the Sixth Circuit Court of Appeals. That has now changed.