Circuit split · bankruptcy law
Whether a creditor's self-interest is relevant to the substantial-contribution analysis for an administrative-expense claim under Bankruptcy Code § 503(b)
1 federal appellate case on this question, each acknowledging the disagreement in its own words.
Ninth Circuit Court of Appeals · July 28, 2004
“There appears to be a conflict among the circuits as to whether a creditor’s self-interest is important to the § 503(b) analysis.” — Split of authority
Empirical analysis of this case →
The other side of the split
Decisions the acknowledging court(s) named as the opposing or joined side, quoted in the acknowledging opinion's own words.
- On the other side · 11th Cir.Speights & Runyan v. Celotex Corp. (In re Celotex Corp.)227 F.3d 1336
“(In re Celotex Corp.), 227 F.3d 1336 , 1338 (11th Cir.2000) (“Examining a creditor’s intent unnecessarily complicates the analysis of whether a contribution of considerable value or worth has been made.”); and Hall Fin.” — Cellular 101, Inc. v. Channel Communications, Inc., acknowledging the split
- On the other side · 5th Cir.Hall Fin. Group v. DP Partners, Ltd. P'ship (In re DP Partners Ltd. P'ship)106 F.3d 667
- On the other side · 3d Cir.Lebron v. Mechem Fin. Inc.27 F.3d 937
- On the other side · 10th Cir.Haskins v. United States (In re Lister)846 F.2d 55
“which are designed primarily to serve their own interests.”); and Haskins v.” — Cellular 101, Inc. v. Channel Communications, Inc., acknowledging the split
What the split turns on
- Statutes:
- § 503(b)
- Doctrines & tests:
- substantial contribution
Cases are grouped by the legal question they announce a split on, classified from the court's own acknowledgment sentence. Verified acknowledgments only. Counter-side decisions are extracted from the acknowledging opinions' own text and linked only when the citation resolves in this corpus. See all circuit splits.