The Most Important Bankruptcy Supreme Court Cases - Free Essay Example

Sample details Pages: 4 Words: 1336 Downloads: 5 Date added: 2019/08/08 Category Law Essay Level High school Tags: Supreme Court Cases Essay Did you like this example? The Most Important Bankruptcy Supreme Court Cases Issue Whether debtor’s retained counsel could be compensated for the fees and expenses incurred in the defense of its bankruptcy fee application. Facts The Southern District of Texas Bankruptcy Court awarded Baker Botts, LLP, along with Jordan, Hyden, Womber, Culbreth Holzer, PC, approximately $120 million in fees for representing ASARCO, LLC, one of the leading copper producers in the U.S., who filed for Chapter 11. As the bankruptcy court noted in its initial fee award order, the DOJ described the ASARCO case as â€Å"the largest environmental bankruptcy in U.S. history.† In 2009 ASARCO emerged with a reorganization plan that would pay its creditors in full, $1.4 billion in cash and resolution of its environmental liabilities. Don’t waste time! Our writers will create an original "The Most Important Bankruptcy Supreme Court Cases" essay for you Create order Baker Botts filed for a final fee request, which ASARCO contested. After extensive discovery and a 6-day trial, the Bankruptcy Court overruled the objections and awarded $120 million in compensation, $4.1 million as an â€Å"enhancement for exceptional performance,† and $5 million in fees for defending the applications. The district court affirmed. The U.S. Court of Appeals for the Fifth Circuit held that the Bankruptcy Code did not allow the firms to recover $5 million spent defending the fee request against Asarcos opposition. The Fifth Circuit held that (i) the American Rule (discussed below) controls absent explicit statutory authority providing reimbursement of defense fees and (ii) defense fees fall outside of  §330(a)(1)’s requirement that services are only compensable â€Å"if they are likely to benefit a debtor’s estate or are necessary to case administration† because the professional, not the estate, is the â€Å"primary beneficiary of a profe ssional fee application.† The Supreme Court then granted certiorari and heard oral argument on February 25, 2015. Holding On June 15, 2015, the Supreme Court affirmed the judgment of the Fifth Circuit in finding that fee defense costs were not recoverable. Justice Thomas wrote the opinion for a six Justice majority (Justice Sotomayor concurring for purposes of the outcome). Justice Breyer dissented, joined by Justices Kagan and Ginsburg. The Supreme Court’s review of the language of Bankruptcy Code  §330(a)(1) led the Court to conclude that it did not provide the sort of â€Å"explicit statutory authority† necessary to override the American Rule and therefore bankruptcy professionals employed under  §327(a) of the Bankruptcy Code may not, under  §330(a)(1) of the Bankruptcy Code, recover as compensation fees incurred in defending their bankruptcy fee applications. The Court’s majority stated, â€Å"[t]he word ‘services’ ordinarily refers to ‘labor performed for another.’† Since Baker Botts was litigating to defend its own fees, the Court reason ed that it was not providing an â€Å"actual, necessary service† to the bankruptcy estate and therefore was not entitled to compensation for such time. Baker Botts’ Significance and Aftermath Following the issuance of the Baker Botts opinion, bankruptcy professionals have raised concerns that the ruling will lead to litigants tactically using fee objections to pressure debtors and their retained professionals. However, since the Baker Botts decision questions have been raised whether there is a possible workaround. That question has been tested in cases since Baker Botts. For example, in the Delaware cases In re Boomerang Tube, LLC, et al. Case No. 15-11247 (MFW) and In re Northshore Mainland Services, Inc., et al. (15-11402-KJC) (a/k/a the Baha Mar case), the bankruptcy court declined to allow Baker Botts ruling to be avoided by contract.   In the Boomerang case, the law firm for the official committee of unsecured creditors asked for the fee approval order to include a provision that would entitle it to be compensated from the bankruptcy estate for fees incurred in defending its fees against any challenges. The law firm relied upon  §328 of the Bankruptcy Code, which allows for the retention of estate professionals â€Å"on any reasonable terms and conditions† arguing that the Supreme Court in Baker Botts recognized that parties could and regularly did contract around the American Rule. The Boomerang Court denied the request and held that  §328 does not create a statutory exception to the American Rule, because it does not mention awarding fees or costs in the context of an adversarial proceeding. In support of the court’s ruling, the Boomerang Court rejected the law firm’s argument that  §328 permitted a contractual agreement for the payment of defense fees because the retention agreement was between the law firm and the official creditors’ committee, but it would be Boomerang Tube’s bankruptcy estate, a non-party to such agreement, that would bear the costs.   Finally, the Boomerang Court determined that the proposed fee shifting provisions were not â€Å"reasonable† terms of employment of professionals with the meaning of  §328. However, decisions in two other cases, In re Nortel Networks, 2017 Bankr. LEXIS 674 (Bankr. D. Del. Mar. 8, 2017) and in a New Mexico case, In re Hungry Horse LLC, Case No. 16-11222, distinguished Boomerang Tube and permitted contractual provisions that allow payment for the defense of fees.   Nortel Networks that Baker Botts and Boomerang Tube did not apply to a fee dispute between an indenture trustee and certain bondholders, and permitted the trustee to recover its attorneys’ fees for defending against the challenge.   Although this case is not directly on point as it did not involve an estate professional, and Judge Gross was not opining on whether Section 328 would permit such an agreement, he held that the bond indenture qualified as a contractual exception to the American Rule, noting that, unlike the retention agreement in Boomerang Tube, it was an agreement directly between the debtor and the trustee. In Hungry Horse New Mexico Bankruptcy Judge David Thuma looked to Nortel Networks for support in holding that a retention agreement in a chapter 11 case between proposed debtor’s counsel and the debtor could pass muster under Section 328, thereby permitting a contractual work-around to Baker Botts.   Judge Thuma first determined that nothing in Baker Botts prevented a bankruptcy court from finding a fee defense provision in a retention agreement to be â€Å"reasonable† within the meaning of Section 328.   In his reading of Baker Botts, the Court simply limited the compensation an estate professional could receive under Section 330 to fees for services to the client, rather than on its own behalf, and noted that Section 328 had no applicability to that issue. He then considered various other provisions typical of retention agreements, and observed that several were â€Å"reasonable† under Section 328 even if they were intended to favor the professional, rather than the client. He pointed to provisions, among other things, setting out retainer requirements, permitting an attorney to withdraw under certain conditions, and granting a lien on certain recoveries.   â€Å"A typical employment agreement between a lawyer and a client has many terms; some benefit the client, while others benefit the lawyer.   Considered together, they may be reasonable.†Ã‚   The overall effect, he noted, is that â€Å"the client obtains the services of needed, able professionals.† Judge Thuma concluded that Section 328 therefore can permit contractual exceptions to the American Rule, and outlined the terms of a fee defense provision in a retention agreement that he believed was â€Å"reasonable† and â€Å"violat[ed] neither the letter nor spirit of [Baker Botts].†Ã‚   He stated that, among other things, it needed to be agreed to by the bankruptcy estate, in order to avoid the issue highlighted by Judge Walrath in Boomerang Tube, and provided also that it extended to the creditors’ committee’s professionals, in order to â€Å"level the playing field.†Ã‚   He suggested sample language that he believed could be acceptable under Section 328: Fee Defense. The Client agrees to pay all reasonable legal fees and expenses incurred by the Firm, and also by any counsel retained by the unsecured creditors’ committee (if one is formed in the Client’s bankruptcy case) for successfully defending their respective fee applications. The bankruptcy court must approve all of such fees as reasonable. The Client will have no obligation to pay for any fees or expenses the Firm incurs defending fees that are not allowed. The pragmatic approach taken in Hungry Horse in particular offers a template that other courts will likely be urged to adopt. https://www.abi.org/feed-item/delaware-takes-on-baker-botts-v-asarco-fee-defense-costs

Police Misconduct and Corruption - 2063 Words

INTRODUCTION For as long as policing has existed in America, there has been misconduct and corruption associated with any given policing agency. Police officer malfeasance can range from minor cases of misconduct to the downright criminal acts that are considered to be corruption. It is important to state here that not all police officers are guilty of misconduct and/or corruption, but like everything in our media-based society, the ?bad? cops are of much more interest and therefore are what this paper will focus on. Merriam-Webster online (2005) defines misconduct as ?1: mismanagement especially of governmental or military responsibilities; 2: intentional wrongdoing; specifically: deliberate violation of a law or standard especially by a†¦show more content†¦Maybe it is because police feel the need to protect themselves when being threatened by a person that they view is capable of causing them major bodily harm. Maybe it is because police band together even if they are in the wrong against people that they view as outsiders that are trying to tell them how to do their job. There are numerous reasons why police misconduct and police corruption aren?t easily defined, but probably the most important one is that not everyone has the same moral standards and a lot of people would define that which is ethical differently. Many justify their behavior by telling themselves that as long as no one else is getting hurt by their actions and as long as no one else finds out about their behavior then what they are doing is okay. Many others still justify their behavior by telling themselves that everyone else only looks out for himself or herself and that they are going to do the same even if it means having to break a few laws and hurt people along the way. WHY MISCONDUCT AND CORRUPTION OCCUR There are several theories as to why police misconduct and corruption occur. One theory centers on the police working personality. According to Schmalleger (2005) police officers share certain characteristics that are part of the police working personality. Insecurity, secrecy, hostility, cynicism, and being individualistic are a few of the characteristicsShow MoreRelatedPolice Corruption and Misconduct2992 Words   |  12 PagesPolice Corruption and Misconduct We all know that Police Officers and those involved in Law Enforcement are typically good people who we entrust to uphold our laws and rules in society. For them to be able to do their job however we grant them several privileges that that empower them more than the average citizen. Their status at times can make them appear above the law since they are the ones upholding and enforcing it and with all due respect I believe mostly of those individuals are responsibleRead MorePolice Misconduct and Corruption1757 Words   |  8 PagesWeek 1 Assignment In order for a Police agency to prevent and deter Police misconduct, there must be a definition to what actions and behaviors that the term will encompass. The term ‘police corruption’ has been used to describe many activities: bribery; violence and brutality; fabrication and destruction of evidence; racism; favoritism or nepotism. Many different scholars differ in their own examples of the definition. Before attempting to the question of whether a precise definition is possibleRead More Police Corruption and Misconduct Essay1684 Words   |  7 Pages Police corruption and misconduct come apparent in many different forms. A basic definition for police corruption is, when an officer gets involved in offenses where the officer uses his or her position, by act or omission, to obtain improper financial benefit. The main reason for such corruption is typically for personal gain, such as bribery. Police abuse of authority occurs in three different general areas such as physical abuse, psychological abuse, and legal abuse. Physical abuse is suchRead More Police Misconduct and Corruption Essay2489 Words   |  10 PagesWithin our police system in America, there are gaps and loopholes that give leeway to police officials who either abuse the authority given to them or do not represent the ethical standards that they are expected to live up to by society. Because of the nature of police work, there is a potential for deterioration of these ethical and moral standards through deviance, misconduct, corruption, and favoritism. 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Corruption is causing so much tension between civilians and officers. Not all police officers are corrupt, but the ones who are give a bad reputation to them all. First, what is corruption? Police corruption is the abuse of police authority for personal gain. Corruption may involve profitRead MoreThe Ethics Of The Police Agency Essay1715 Words   |  7 PagesPolice agencies have been traumatized with allegations of corruption and misconduct almost since the inception of law enforcement. In most organizations, an employee investigation is a sensitive issue. The employee being investigated can become unsettled, many times mentally and emotionally exhausted. Employees directly and indirectly involved can also become emotionally drained. Consider the impact an internal affairs investigation has within a police agency as it struggles to maintain the confidence

Persuasive Essay On Abortion - 1635 Words

What is overpopulation? Overpopulation has been defined as a situation where the number of people in an environment exhausts all available resources weakening its needed support. (Morse Mosher) For years there have been reports of how many people are expected to live on earth by the year 2050, 2075, and so on. However, the question remains as to whether everyone will have a secured spot. Today, in 2017 there have been plenty of fights with the scarcity of resources, where overpopulation becomes the topic of conversation. However, to solve this issue the option of abortion was brought to the forefront by scientists and advocates such as Dan Savage who mentioned that abortion should be mandatory for the next 30 years in or to control the†¦show more content†¦population is projected to increase from 319 million to 417 million, reaching 400 million in 2051. The U.S. population is projected to grow more slowly in future decades than in the recent past, as these projections assume that fertility rates will continue to decline and that there will be a modest decline in the overall rate of net inter-national migration†. (Colby Ortman) In addition, according to the most accurate results reported in 2013, the total amount of abortions in the U.S. that year came to be 664,435 in comparison to a number of 3 million births that year. (CDC) As shown in the graph below it’s proven that as abortion rates decrease the population and Medicaid costs increases. Fig. 1. Graph of reported population and abortions from 2010-2013. Credit of cdc.gov Medicaid.gov Considering the thought of raising the number of these medical procedures comes the question of how it will affect society. For those who pay taxes their funds are a contribution to the Title X portion of federal funding, who is estimated to spend about 385 billion dollars on Medicaid this year. (CBO) For those who have private insurance, services are paid for directly out of pocket, but in the case of low-income families who receive Medicaid or government assistance, the battle over Planned Parenthood is the main contender. Under the workings of the Public Service Health Act government funding contributes to the services of family planning health centers such as PlannedShow MoreRelatedPersuasive Essay About Abortion993 Words   |  4 Pagesin two peoples perspectives. The story consisted of a daughter (Deb) and mother’s perspective after the death of her father. The purpose of this layout is to show how they are both grieving in individual ways. Writing for the persuasive wa s presented as an essay on why abortion should be accessible in every country, and to also outline the shame women receive. Purpose Purpose for writing publication- Purpose for writing a real-estate article was to inform a potential buyer on the house showed. AlsoRead MoreAbortion Persuasive Essay1119 Words   |  5 Pages To begin with, there has always been an extensive issue with the topic of abortion, why? Well, it’s a tough subject and can get extremely emotional and very defensive. Honestly, people just need to open up their eye’s and understand that its murder and not just a choice. It is murder because two can create a blessing and the choice of aborting it, is more like a sacrifice for the reason a mother can’t carry a baby for nine months. Whether a person is a minor, young adult, or an adult and is inRead MoreAbortion Persuasive Essay755 Words   |  4 Pagesinstead these babies are torn limb by limb, burned, and many other tortuous methods to end the precious life. Abortion is murder and is not only very cruel to the unborn baby but it also harms the mother. Pro-choice is an escape from the harsh reality that a baby is being murdered, and in my eyes a life should only be terminated if God himself is ready to call them home. 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Because of the numerous traumatic psychological, physical, and overall irresponsible behavior or actions constantly encouraged due to abortio n, it should be banned, and forever illegal. Killing one’s own fetus has been linked to psychological distress which has been channeled into many different cases of substance abuse. â€Å"Induced abortion has been linked to increased rates of substance abuse, especially amongRead MoreAbortion Persuasive Essay804 Words   |  4 Pagesfamily with someone. Often times accidents happen in which people didn’t plan for, and can lead to many financial problems or neglect of one’s child because the parents weren’t prepared to be parents. This is why there should be the option of abortion. Abortion needs to be an option for everyone because it helps from long lasting mental states, infection, economical problems, and or having conceived from a non consensual circumstance. Pregnancy is a hard and unforgiving to the woman’s body. In factRead MorePersuasive Essay On Abortion954 Words   |  4 Pagesand nations who destroy life by abortion and euthanasia are the poorest. I do not say legal or illegal, but I think that no human hand should be raised to kill life, since life is God’s life in us, even in an unborn child.† Do you know what abortion really is? Abortion is the ending of pregnancy by removing a fetus or embryo before it can survive outside the uterus. Abortion seems to be more common in today’s society. Numerous amounts of individuals support abortion, and do not realize how it affectsRead MoreAbortion Persuasive Essay736 Words   |  3 Pagesfavor of abortion rights. The decision was 7-2, it stated that it showed a â€Å"right of privacy.†Abortions have been performed for thousands of years all around the world, even though many women died from it. Women nowadays have a choice of whether they want to get an abortion. Abortions do come with risk, one of them being death, but women should still have a right and say what they want to do with pregnancy and not be judged by others for doing so. Today the debate across the world is if abortion shouldRead MorePersuasive Essay On Abortion1321 Words   |  6 Pagessomeone who may be suicidal or who is suicidal himself/herself. As for taking away fetus’ lives, the damage that abortion makes on life can be proven with the statistics. According to Casey, â€Å"over the past 44 years, one-sixth (60,000,000) of the American population has been killed by elective abortion. Twenty-five percent of African-Americans are killed in the womb America,† (Should Abortion Be Legal n.p.). The figure 60,000,000 is a depressing number considering that these children could have been futureRead MorePersuasive Essay On Abortion723 Words   |  3 Pagescontraception I want to discuss is sterilization. For an idea that is so broadly accepted in private, contraception certainly generates a lot of opposition when discussed in public. Some people think when we talk about contraception that it’s code for abortion. It’s obviously not the same thing. Let’s be honest, people are just uncomfortable with the topic because it’s about sex. And sex talk in this country is kept on the hush even though we are sold sex via advertising left and right. Some people worry

Bipolar Disorder Cause of Great Madness or Great G Essay Example For Students

Bipolar Disorder Cause of Great Madness or Great G Essay enius Essay written by Is bipolar disorder the cause of great madness or great genius? The symptoms of this mental illness may also be considered as the driving forces behind some of the most gifted and talented people to grace our society. Although individuals with this illness may have some obstacles to overcome, it can be accomplished. With all of the treatment programs that are widely available, people have many options and methods to turn to for help. Bipolar disorder, also referred to as manic depression, is a mood disorder. A person with bipolar disorder will have extreme mood shifts between mania, a state of highly elevated euphoric feelings, and depression, a state of despondency and despair. These shifts can take weeks, days, or even minutes to happen. The period between shifts will vary for each individual, depending on the severity of the disorder (Williams Wilkins, 1999, pp. 5-35). Approximately two percent of adults have this mental illness, and about fifteen percent of those adults will attempt suicide. Bipolar disorder affects both men and women and the affected rates are similar between different cultures and countries. Most people with bipolar disorder experience their first mood episode in their twenties, although it is not uncommon to experience the first episode during childhood or in late life (Bi-polar Disorder: Innovative Research in Health, 2000). Bipolar disorder is not a curable disorder, although it is treatable. Bipolar is among the most treatable of the psychiatric illnesses (Manic-Depressive/Bipolar Disorder, 2000). It is important for people who believe that they may need help to seek it as soon as possible because the earlier that bipolar disorder can be diagnosed the earlier treatments can start. Even after experiencing an episode, even after sensing that something may be wrong, individuals who seek help may not initially receive the correct diagnosis from a medical professional. Because of the similarity of symptoms, bipolar disorder may initially be misdiagnosed as panic disorder, schizophrenia, or attention deficit disorder (Bi-polar Disorder: Innovative Research in Health, 2000). Bipolar may also be difficult to diagnose because the person seeking help may not be telling the doctor everything the doctor needs to know to correctly identify the problem. Medical professionals may only diagnose a person as having depression because they have no knowledge of the excessive enthusiasm that the patient feels. It is important for individuals seeking medical help to be accurate and thorough in describing their feelings or symptoms (Manic-Depressive/Bipolar Disorder, 2000). A person experiencing a manic episode may have increased energy and/or racing thoughts. Feelings of euphoria and/or an increased pressure to talk may also be symptoms. A person in this stage of the illness may have uncharacteristically poor judgement and/or may be involved in some type of high-risk behavior, such as uncontrollable spending sprees, habitual reckless driving and/or participating in unusual sexual encounters and behaviors. Usually the individual denies that anything is wrong when in a manic state (Manic-Depressive/Bipolar Disorder, 2000). A person experiencing the depression state of bipolar disorder may have feelings of worthlessness and/or guilt. Decreased energy and/or loss of interest in once pleasurable activities may also be symptoms of clinical depression. A depressed person may have trouble concentrating and/or have trouble making decisions. Depression may also leave individuals contemplating suicide (Manic-Depressive/Bipolar Disorder, 2000). There are two classifications for bipolar disorder, bipolar II and bipolar I (Williams Wilkins, 1999, pp. 5-35). The combination and degree of mania and depression determine the type of bipolar illness. It is also determined by how long each stage lasts and the time frame of euthymia, having normal moods, between stages. The cycling of stages may overlap, which is referred to as a mixed episode. The diagnostic system that is currently being used by mental health professionals is the Diagnostic and Statistical Manual of Mental Disorders volume four, also known as DSM-IV (Manic- Depressive/Bipolar Disorder, 2000). A patient diagnosed as having bipolar II disorder has or has had at least one episode of major depression and is experiencing or has experienced one or more episodes of hypomania. Hypomanic episodes have the same symptoms of mania only to a lesser degree. .ua9bfb9688f7f14abbb73dfc00e222a09 , .ua9bfb9688f7f14abbb73dfc00e222a09 .postImageUrl , .ua9bfb9688f7f14abbb73dfc00e222a09 .centered-text-area { min-height: 80px; position: relative; } .ua9bfb9688f7f14abbb73dfc00e222a09 , .ua9bfb9688f7f14abbb73dfc00e222a09:hover , .ua9bfb9688f7f14abbb73dfc00e222a09:visited , .ua9bfb9688f7f14abbb73dfc00e222a09:active { border:0!important; } .ua9bfb9688f7f14abbb73dfc00e222a09 .clearfix:after { content: ""; display: table; clear: both; } .ua9bfb9688f7f14abbb73dfc00e222a09 { display: block; transition: background-color 250ms; webkit-transition: background-color 250ms; width: 100%; opacity: 1; transition: opacity 250ms; webkit-transition: opacity 250ms; background-color: #95A5A6; } .ua9bfb9688f7f14abbb73dfc00e222a09:active , .ua9bfb9688f7f14abbb73dfc00e222a09:hover { opacity: 1; transition: opacity 250ms; webkit-transition: opacity 250ms; background-color: #2C3E50; } .ua9bfb9688f7f14abbb73dfc00e222a09 .centered-text-area { width: 100%; position: relative ; } .ua9bfb9688f7f14abbb73dfc00e222a09 .ctaText { border-bottom: 0 solid #fff; color: #2980B9; font-size: 16px; font-weight: bold; margin: 0; padding: 0; text-decoration: underline; } .ua9bfb9688f7f14abbb73dfc00e222a09 .postTitle { color: #FFFFFF; font-size: 16px; font-weight: 600; margin: 0; padding: 0; width: 100%; } .ua9bfb9688f7f14abbb73dfc00e222a09 .ctaButton { background-color: #7F8C8D!important; color: #2980B9; border: none; border-radius: 3px; box-shadow: none; font-size: 14px; font-weight: bold; line-height: 26px; moz-border-radius: 3px; text-align: center; text-decoration: none; text-shadow: none; width: 80px; min-height: 80px; background: url(https://artscolumbia.org/wp-content/plugins/intelly-related-posts/assets/images/simple-arrow.png)no-repeat; position: absolute; right: 0; top: 0; } .ua9bfb9688f7f14abbb73dfc00e222a09:hover .ctaButton { background-color: #34495E!important; } .ua9bfb9688f7f14abbb73dfc00e222a09 .centered-text { display: table; height: 80px; padding-left : 18px; top: 0; } .ua9bfb9688f7f14abbb73dfc00e222a09 .ua9bfb9688f7f14abbb73dfc00e222a09-content { display: table-cell; margin: 0; padding: 0; padding-right: 108px; position: relative; vertical-align: middle; width: 100%; } .ua9bfb9688f7f14abbb73dfc00e222a09:after { content: ""; display: block; clear: both; } READ: Sectionalism 1820-1860 Essay It is important for treatment to start .