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    Seventh Circuit Overturns Bankruptcy Precedent, Finds Transfer Occurs When Money is Paid
    2023-02-07

    On January 9, the Seventh Circuit overturned its own 39-year-old precedent to find that: (1) the definition of “transfer” for purposes of section 547 of the Bankruptcy Code depends on federal, not state, law; and (2) the date of “transfer” is the time at which the money passes to the creditor’s control.

    Filed under:
    USA, Insolvency & Restructuring, Litigation, Troutman Pepper, Supreme Court of the United States
    Authors:
    Deborah Kovsky-Apap
    Location:
    USA
    Firm:
    Troutman Pepper
    High Court Decisions of Bryant v Badenoch Integrated Logging Pty Ltd and Metal Manufactures Pty Limited v Morton
    2023-02-08

    The first High Court decisions in 2023; Metal Manufactures Pty Limited v Morton Metal Manufactures Pty Limited v Morton [2023] HCA 1 (‘Metal Manufactures’) and Bryant v Badenoch Integrated Logging Pty Ltd [2023] HCA 2 (‘Bryant’) have provided the final word on preference claims, establishing once and for all that:

    1. set-off under s 553C of the Corporations Act 2001 (Cth) (‘the Act’) does not apply to unfair transactions; and

    2. the peak indebtedness rule does not apply.

    Filed under:
    Australia, Insolvency & Restructuring, Litigation, Piper Alderman, Corporations Act 2001 (Australia)
    Authors:
    Angelina Kozary
    Location:
    Australia
    Firm:
    Piper Alderman
    Under the NCC, money borrowed for residential property purposes must be for the borrower’s sole use
    2023-02-06

    MAG Financial and Investment Ventures Pty Ltd v El-Saafin [2022] VSCA 286

    The Victorian Court of Appeal has recently held that credit provided under the National Credit Code (“the NCC”) to purchase, renovate or improve residential property for investment purposes is restricted to the immediate use of the debtor.

    Filed under:
    Australia, Victoria, Banking, Insolvency & Restructuring, Litigation, Real Estate, The Commercial Bar Association of Victoria
    Authors:
    Christopher A Connor
    Location:
    Australia
    Firm:
    The Commercial Bar Association of Victoria
    Creditor that Filed an Excessive Claim Draws Court’s Rebuke and Possible Sanctions
    2023-02-06

    This post is about a junkyard, hogs getting slaughtered, and a bankruptcy judge poised to sanction a creditor and her counsel. The message from the case to would-be claimants in other cases is simple: do not “overreach.”In re U Lock, Inc., Case No. 22-20823, 2023 WL 308210, at *1 (Bankr. W.D. Pa. Jan. 17, 2023).

    Filed under:
    USA, Company & Commercial, Insolvency & Restructuring, Litigation, Patterson Belknap Webb & Tyler LLP, Bankruptcy, Mediation
    Authors:
    Daniel A. Lowenthal
    Location:
    USA
    Firm:
    Patterson Belknap Webb & Tyler LLP
    The Music Stops on the Texas Two-Step: Third Circuit Dismisses LTL Bankruptcy Case
    2023-02-06

    The United States Court of Appeals for the Third Circuit wasted no time getting the new year off to a roaring start through its ruling in In re LTL Mgmt., LLC, Case No. 22-2003, 2023 WL 1098189 (3d Cir. Jan. 30, 2023). In LTL, the Third Circuit affirmatively dismissed the so-called “Texas Two-Step” by which a solvent corporation had tried to cabin potentially billions of dollars of mass tort liability through an internal corporate restructuring.

    In that ruling, the Third Circuit determined that:

    Filed under:
    USA, Insolvency & Restructuring, Litigation, Ropes & Gray LLP, Third Circuit, U.S. Court of Appeals
    Authors:
    Ryan Preston Dahl
    Location:
    USA
    Firm:
    Ropes & Gray LLP
    Third Circuit Dismisses J&J Bankruptcy Case for Lack of Good Faith
    2023-02-06

    “The theme is clear: absent financial distress, there is no reason for Chapter 11 and no valid bankruptcy purpose.”

    Filed under:
    USA, Insolvency & Restructuring, Litigation, Schulte Roth & Zabel LLP, Bankruptcy, Good faith, Johnson & Johnson, Third Circuit
    Authors:
    Douglas S. Mintz , Kelly (Bucky) Knight , Robert D. Brown
    Location:
    USA
    Firm:
    Schulte Roth & Zabel LLP
    The Supreme Court has refused a debtor permission to appeal against a bankruptcy order in the case of Howell v Hughes & Hughes
    2023-02-06

    Mr and Mrs Hughes had granted a tenancy of a house to Mr Howell. He did not pay all of the rent and so they instructed Eleanor Solomon of Anthony Gold who issued possession proceedings. In September 2015 a possession order and money judgment were made against him. He did not satisfy the judgment debt and a bankruptcy petition was presented.

    Filed under:
    United Kingdom, Insolvency & Restructuring, Litigation, Anthony Gold, Bankruptcy
    Authors:
    Clifford Tibber
    Location:
    United Kingdom
    Firm:
    Anthony Gold
    Third Circuit’s Choice Of Huge Disparities For Similarly Situated Claimants Is Inexplicable (Johnson & Johnson)
    2023-02-07

    Johnson & Johnson (“J&J”) has, for a very long time, produced and sold a baby powder product containing talc—a mineral milled into fine powder that includes traces of asbestos.

    In recent years, that baby powder product has spawned a torrent of lawsuits alleging that it causes ovarian cancer and mesothelioma.

    Currently, over 38,000 ovarian cancer actions and over 400 mesothelioma actions are pending against J&J. Expectations are for thousands more to be filed in decades to come.

    Filed under:
    USA, Insolvency & Restructuring, Litigation, Koley Jessen PC, United States bankruptcy court
    Authors:
    Donald L. Swanson
    Location:
    USA
    Firm:
    Koley Jessen PC
    The ipso facto stay in voluntary administration: first decision gives some (limited) guidance
    2023-02-07

    The first reported decision on the ipso facto stay provisions of the Corporations Act provides clarity that they operate as intended in voluntary administration – leaving the trickier issues for another day.

    Filed under:
    Australia, Insolvency & Restructuring, Litigation, Clayton Utz, ipso facto, Corporations Act 2001 (Australia)
    Authors:
    Mikhail Glavac
    Location:
    Australia
    Firm:
    Clayton Utz
    The Unfair Contradiction of the Conflict of State and Federal Laws on the Bankruptcy Proceedings of Dispensary Employees
    2023-02-07

    There is seemingly, in the opinion of a great number of bankruptcy courts, a conflict between the United States Bankruptcy Code requirements that a debtor reorganize or liquidate “in good faith,” the federal Controlled Substances Act [21 USC § 841] (“CSA”) prohibiting, among other things, the distribution or sale of marijuana, and the laws of over half of the states in the country that authorize the sale of marijuana for medical and other purposes.

    Filed under:
    USA, Insolvency & Restructuring, Litigation, Nelson Mullins Riley & Scarborough LLP, Cannabis, US Congress, Supreme Court of the United States
    Authors:
    Peter J. Haley
    Location:
    USA
    Firm:
    Nelson Mullins Riley & Scarborough LLP

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