On May 12, 2026, Chief Judge Martin Glenn of the United States Bankruptcy Court for the Southern District of New York issued a 27-page memorandum opinion in In re Iovate Health Sciences International Inc., Case No. 25-11958 (MG), recognizing and enforcing an Approval and Reverse Vesting Order entered by the Ontario Superior Court of
Third-Party Releases
Cumulus Media: Judge Pérez Confirms Prepackaged Plan Over U.S. Trustee’s Opt-Out Release Objection
By Carl D. Neff on
On April 15, 2026, Judge Alfredo R. Pérez of the United States Bankruptcy Court for the Southern District of Texas confirmed the modified joint prepackaged Chapter 11 plan of Cumulus Media Inc. and its debtor affiliates at the conclusion of a 48-minute hearing in Houston. The U.S. Trustee for Region 7, Kevin Epstein, was the…
SDNY Rejects Opt-Out Releases in Chapter 11 Plan, Deepening Post-Purdue Uncertainty
By Carl D. Neff on
On December 1, 2025, the U.S. District Court for the Southern District of New York issued a decision in In re GOL Linhas Aéreas Inteligentes S.A., 675 B.R. 125 (S.D.N.Y. 2025), reversing a bankruptcy court’s confirmation of third-party releases that relied on an opt-out mechanism. Judge Denise Cote held that a creditor’s silence—a failure…
How Far Can a Plan Injunction Reach? Delaware Weighs In on Gatekeeping
By Carl D. Neff on
On August 21, 2025, Judge Craig T. Goldblatt of the United States Bankruptcy Court for the District of Delaware issued a significant ruling in In re AIO US, Inc. (the Avon Products bankruptcy) that rejected a “gatekeeping” provision in a proposed Chapter 11 plan. The court held that neither the Bankruptcy Code nor the Barton…