Justia U.S. 1st Circuit Court of Appeals Opinion Summaries

A Puerto Rico agency, the Milk Industry Regulatory Office (ORIL), revoked a dairy farmer's license and ordered him to sell his milk production quota rights. When the farmer, Luis Manuel Ruiz Ruiz, failed to comply, ORIL planned to auction the quota rights. Ruiz, who had filed for Chapter 12 bankruptcy in 2015, argued that the auction violated the automatic stay provision of the Bankruptcy Code.The bankruptcy court enjoined ORIL from auctioning the quota without court permission, finding that the planned auction violated the automatic stay. The court granted partial summary judgment to Ruiz, determining that ORIL's actions were not protected by the police power exception. ORIL appealed to the United States District Court for the District of Puerto Rico, which affirmed the bankruptcy court's decision, agreeing that the police power exception did not apply.The United States Court of Appeals for the First Circuit reviewed the case. The court held that ORIL's plan to auction Ruiz's milk quota fell within the police power exception to the automatic stay under 11 U.S.C. § 362(b)(4). The court reasoned that the auction was part of enforcing a judgment obtained in an action to enforce ORIL's regulatory power, which is not a money judgment. The court emphasized that ORIL's actions were aimed at protecting public health and welfare by regulating milk production and distribution, rather than advancing a pecuniary interest.The First Circuit reversed the judgments of the bankruptcy and district courts, directing judgment in favor of ORIL. The court concluded that ORIL's planned auction did not violate the automatic stay and was protected by the police power exception. View "Milk Industry Regulatory Office v. Ruiz Ruiz" on Justia Law

The case involves Edgar Reyes-Colón, who was subjected to an involuntary Chapter 11 bankruptcy petition filed by Banco Popular de Puerto Rico in 2006. The bankruptcy court dismissed the petition in 2016, finding that Banco Popular failed to join the requisite number of creditors. Reyes-Colón subsequently filed a motion for attorney's fees and costs under 11 U.S.C. § 303(i)(1) and initiated an adversary proceeding alleging bad faith under 11 U.S.C. § 303(i)(2).The bankruptcy court denied Reyes-Colón's motion for attorney's fees, ruling it lacked subject-matter jurisdiction as the motion was filed after the case was closed. Reyes-Colón appealed to the District Court for the District of Puerto Rico, which affirmed the bankruptcy court's decision, adding that the motion was untimely under local rules requiring such motions to be filed within fourteen days after the issuance of the mandate. Reyes-Colón then appealed to the United States Court of Appeals for the First Circuit.The First Circuit held that the bankruptcy court had jurisdiction over post-dismissal § 303(i) motions, as such motions necessarily require post-dismissal jurisdiction. However, the court affirmed the denial of the attorney's fees motion on the grounds that it was untimely, as it was filed 365 days after the mandate issued, far exceeding the fourteen-day limit set by local rules.Regarding the adversary proceeding, Reyes-Colón filed a motion for withdrawal of reference to have the district court adjudicate the case. The district court denied the motion as untimely, conflating the timeliness of the motion for withdrawal with the timeliness of the § 303(i) motion. The First Circuit vacated this decision, clarifying that the timeliness of the motion for withdrawal should be measured from the filing of the adversary proceeding, not the dismissal of the involuntary petition. The case was remanded for further consideration of whether there is cause to withdraw the reference. View "Reyes-Colon v. Banco Popular de Puerto Rico" on Justia Law

The case involves Puerto Rico's attempt to enact Law 29, which aimed to relieve municipalities from contributing to the Commonwealth's reformed public pension funding scheme. The Financial Oversight and Management Board for Puerto Rico (the Board) challenged the law, and the Title III court overseeing Puerto Rico's debt restructuring declared Law 29 a nullity and of no effect. This decision was not appealed. La Liga de Ciudades de Puerto Rico (La Liga) argued that the Title III court's order did not authorize the Board to recover funds retained by municipalities under Law 29 before the order took effect.The United States District Court for the District of Puerto Rico, interpreting its own prior order, granted motions to dismiss filed by the Board and other defendants. The court dismissed some claims on the merits and others for lack of standing. The court held that the Title III court's order applied retroactively, nullifying Law 29 from its inception and allowing the Board to recover the funds.The United States Court of Appeals for the First Circuit reviewed the case. The court affirmed the district court's dismissal of La Liga's complaint. It held that the Title III court's order declaring Law 29 a nullity and of no effect applied retroactively, covering the period from the law's enactment. The court found that the Title III court had the authority under PROMESA to nullify Law 29 from its inception and that the Board's actions to recover the funds were justified. The court also addressed standing issues, affirming that La Liga had standing to sue the Board and CRIM but not the executive branch defendants. View "La Liga de Ciudades de P.R. v. Financial Oversight and Management Board" on Justia Law

The case involves a dispute over the rights of parties holding certain revenue bonds issued by the Puerto Rico Electric Power Authority ("PREPA") before it entered reorganization proceedings under Title III of the Puerto Rico Oversight, Management, and Economic Stability Act ("PROMESA"). The Financial Oversight and Management Board for Puerto Rico ("the Board") filed an adversary proceeding within the Title III restructuring proceeding to define the rights and remedies that bondholders had against PREPA. The United States District Court for the District of Puerto Rico held that the bondholders only had a secured claim on moneys deposited into the Sinking and Subordinate Funds, and that the bondholders had an unsecured claim on PREPA's Net Revenues.The United States Court of Appeals for the First Circuit disagreed with the district court's findings. The appellate court held that the bondholders have a lien on PREPA's present and future Net Revenues, and that the bondholders' lien is not avoidable. The court also held that the proper amount of the bondholders' claim is the face value (i.e., principal plus matured interest) of the Revenue Bonds. The court affirmed the district court's dismissal of the bondholders' breach of trust claim, but reversed the dismissal of the bondholders' accounting claim. The case was remanded for further proceedings consistent with the appellate court's opinion. View "Financial Oversight and Management Board v. U.S. Bank National Assn." on Justia Law

In this case before the United States Court of Appeals for the First Circuit, five groups of current and former public employees in the Commonwealth of Puerto Rico (the "Commonwealth") appealed an order by the court overseeing the Commonwealth-wide debt restructuring litigation (the "Title III court") on their motions to secure administrative-expense priority for their back pay claims. The back pay claims arose from allegations that their public employers failed to adjust their wages upward, a violation of Puerto Rico law. The Title III court had previously rejected efforts to assert administrative-expense priority for back pay for work performed before the commencement of the Commonwealth's debt restructuring case under Title III of the Puerto Rico Oversight, Management, and Economic Stability Act ("PROMESA").The appellate court affirmed the Title III court's decision. The appellate court agreed that the pre-petition work claims did not qualify for administrative-expense priority under § 503(b)(1)(A)(ii) of the Bankruptcy Code, which is incorporated into PROMESA, because they were not "wages and benefits awarded pursuant to a judicial proceeding . . . as back pay attributable to any period of time occurring after commencement of the case under this title." The appellate court also held that the Title III court did not abuse its discretion in deferring its decision on administrative-expense status for back pay claims concerning work performed post-petition but for which there has not yet been any judgment in the underlying commonwealth court and agency proceedings. View "Abraham Gimenez Plaintiff Group v. FOMB" on Justia Law

In this case, the United States Court of Appeals for the First Circuit considered an appeal from a ruling by the United States District Court for the District of Puerto Rico concerning the restructuring of debts of the Commonwealth of Puerto Rico's public power company (PREPA) under Title III of the Puerto Rico Oversight, Management, and Economic Stability Act (PROMESA). The appellants, GoldenTree Asset Management and Syncora Guarantee (the "Bondholders"), held around $1 billion of PREPA's roughly $8 billion in bonds and sought relief from the automatic stay on actions against PREPA's estate, hoping to appoint a receiver for PREPA.The Bondholders argued that the automatic stay lifted by operation of law, because the district court denied their latest motion for relief without first noticing and holding a hearing within the timeframe prescribed by 11 U.S.C. § 362(e)(1). However, the appellate court held that the Bondholders waived their right to a prompt notice and hearing on that motion for relief. The court reasoned that the Bondholders accepted a litigation schedule that postponed any hearing on their request for leave to seek the appointment of a receiver until after a parallel proceeding about whether—and to what extent—the Bondholders had any collateral to protect in the first place. The court therefore affirmed the judgment of the Title III court. View "GoldenTree Asset Management LP v. Financial Oversight and Management Board" on Justia Law

The First Circuit affirmed the judgment of the bankruptcy court denying Debtor a discharge pursuant to 11 U.S.C. 727(a)(3) for Debtor's failure to keep or preserve records and declined to decide whether a denial was warranted under 11 U.S.C. 727(a)(4) holding that the bankruptcy court properly denied a discharge under section 727(a)(3).Plaintiff filed a Chapter 7 bankruptcy petition. Defendant, who held an unsatisfied judgment against Plaintiff, commenced an adversary proceeding seeking to deny Plaintiff a discharge on five separate grounds. The bankruptcy court denied Plaintiff a discharge pursuant to section 727(a)(3) and also found that the discharge should be denied under section 727(a)(4). The First Circuit affirmed, holding that the bankruptcy court properly denied a discharge pursuant to section 727(a)(3). View "Hernandez v. Shove" on Justia Law

The First Circuit dismissed as moot the appeal brought by the Milk Industry Regulatory Office of the Commonwealth of Puerto Rico (ORIL) challenging two bankruptcy court orders, holding that the action became moot prior to the judgment of the Bankruptcy Appellate Panel (BAP) for the First Circuit affirming the bankruptcy court orders on the merits.The first order at issue granted Luis Manuel Ruiz Ruiz permission to enter a lease in the course of his bankruptcy proceedings, and the second order denied ORIL's motion for reconsideration of that permission. The BAP affirmed the orders on the merits. The First Circuit dismissed ORIL's appeal as moot, vacated the judgment of the BAP, and remanded the case to the BAP with instructions to dismiss ORIL's appeal as moot, holding (1) this case was moot, and there was no exception to the mootness doctrine to save this appeal from dismissal; and (2) the balance of the equities weighed against vacated of the bankruptcy court orders at issue. View "Milk Industry Regulatory Office v. Ruiz Ruiz" on Justia Law

The First Circuit affirmed the order of the bankruptcy court rejecting the valuation method espoused in the Bankruptcy Appellate Panel's (BAP) decision in Snyder v. Rockland Tr. Co., 249 B.R. 40 (1st Cir. B.A.P. 2000), and concluding that Nataly Minkina could avoid a judicial lien under the formula set forth in 11 U.S.C. 522(f), holding that there was no error.At issue was the propriety of the Snyder valuation method for a debtor's interest in property held as a Massachusetts tenant by the entirety for purposes of the lien avoidance formula of section 522(f). Minkina moved to avoid a judicial lien on the grounds that the lien impaired her homestead exemption pursuant to section 522(f). The bankruptcy court departed from the Snyder approach in granting Minkina's motion to avoid. The First Circuit affirmed, holding (1) the BAP's decision in Snyder both misapplied Massachusetts law and impermissibly deviated from the plain text of section 522; and (2) the bankruptcy court's analysis in this case was proper. View "Rodgers, Powers & Schwartz, LLP v. Minkina" on Justia Law

The First Circuit affirmed the rulings of the bankruptcy court in this adversary proceeding brought by Ann Tracy Botelho against her neighbor and business partner, Mary E. Buscone, during Mary's bankruptcy proceedings, holding that there was no error in the challenged rulings.In 2012, Mary and Ann opened up a frozen yogurt shop together. The business ceased operations in 2014, and Ann filed for bankruptcy. In 2018, after Ann received a Chapter 7 discharge, Ann sued Mary in state court, resulting in a default judgment. The court attached a lien for the judgment amount plus interest to Mary's home. Mary then brought her own Chapter 7 case, listing in her schedules Ann's claim against her. Ann subsequently initiated an adversary proceeding seeking a determination that her claim against Mary was non-dischargeable. A prolonged discovery dispute ensued resulting in another default judgment against Mary as a sanction for her failure to comply with discovery orders. The bankruptcy appellate panel largely affirmed the bankruptcy court's rulings. The First Circuit affirmed, holding that the district court did not err in denying Mary's motion for summary judgment, granting Ann's second motion to compel, and denying Mary's motion for reconsideration. View "Botelho v. Buscone" on Justia Law