In re Murray

(United States Second Circuit) – Affirmed the dismissal of a Chapter 7 involuntary bankruptcy petition filed by a debtor’s sole creditor. The debtor argued that the bankruptcy petition should be dismissed because it was simply a judgment enforcement tactic for a two-party dispute for which there were adequate remedies under state law. Agreeing with him, the Second Circuit found that the case would not serve any bankruptcy purposes such as ensuring equal distribution among creditors or otherwise protecting assets from depletion. The panel therefore affirmed dismissal of the involuntary bankruptcy petition.

Financial Oversight and Management Board for Puerto Rico v. Ad Hoc Group of PREPA Bondholders

(United States First Circuit) – Vacated an order denying a request by Puerto Rico Electric Power Authority (PREPA) bondholders for relief from an automatic stay. The bondholders argued that a statute enacted by Congress to address Puerto Rico’s financial crisis did not preclude them from obtaining relief so that they could petition another court to place PREPA into receivership. Agreeing, the First Circuit held that the district court erred in concluding otherwise.

In re Wrightwood Guest Ranch, LLC

(United States Ninth Circuit) – Affirmed the denial of two law firms’ challenges to a court-approved Chapter 11 bankruptcy settlement. The law firms, which represented the debtor and the unsecured creditors’ committee, sought to challenge the settlement on their own behalf. Finding that neither law firm, on its own behalf, had objected to the settlement at the time, the Ninth Circuit ruled that the firms had forfeited their objections and, in any event, the bankruptcy court did not plainly err in approving the settlement agreement.