11 U.S.C. § 1144
Section 1144 · Revocation of an order of confirmation
Amended 2 times on record
Applied in 205 court decisions — leading case Kham & Nate's Shoes No. 2, Inc. v. First Bank of Whiting (1990)
Most recently applied in 2021 IL App (1st) 201279 - Donahue v. Demma (December 2021)
Cases citing this section usually also cite 11 U.S.C. § 1141 · 11 U.S.C. § 1129 · 28 U.S.C. § 157
How often courts cite this section
Court decisions citing this, by year.Markers show enactment, consequential amendments, and circuit splits over this section — watch for a citation surge after a change or a disagreement. The dip in the last several years is a data-coverage gap, not a real trend — our corpus holds fewer opinions from the most recent years, so recent citations are undercounted.
On request of a party in interest at any time before 180 days after the date of the entry of the order of confirmation, and after notice and a hearing, the court may revoke such order if and only if such order was procured by fraud. An order under this section revoking an order of confirmation shall—
(1) contain such provisions as are necessary to protect any entity acquiring rights in good faith reliance on the order of confirmation; and
(2) revoke the discharge of the debtor.
Editorial notes U.S. Code · Office of the Law Revision Counsel
Historical and Revision Notes
If an order of confirmation was procured by fraud, then the court may revoke the order on request of a party in interest if the request is made before 180 days after the date of the entry of the order of confirmation. The order revoking the order of confirmation must revoke the discharge of the debtor, and contain such provisions as are necessary to protect any entity acquiring rights in good faith reliance on the order of confirmation.
Amendments
1984—Pub. L. 98–353 inserted “if and only” after “revoke such order”.
Effective Date of 1984 Amendment
Amendment by Pub. L. 98–353 effective with respect to cases filed 90 days after July 10, 1984, see section 552(a) of Pub. L. 98–353, set out as a note under section 101 of this title.