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Volume XVIII, Issue 28

July 17, 2025

 

Johnson v. Mazie, Case Nos. 24-1946 & 24-2056 (3rd Cir. 2025).

Ancillary enforcement jurisdiction does not confer “original jurisdiction” sufficient to permit removal under 28 U.S.C. § 1441(a).

 

Benshot, LLC v. 2 Monkey Trading, LLC (In Re: 2 Monkey Trading, LLC), Case No. 23-12342 (11th Cir. 2025).

Neither individual nor corporate debtors can discharge debts listed under § 523(a) in Subchapter V proceedings.

 

AST & Science LLC v. Delclaux Partners SA, Case No. 23-11985 (11th Cir. 2025).

Federal jurisdiction over state law claims exists only in the very narrow circumstances set forth in Grable & Sons Metal Products, Inc. v. Darue Engineering & Manufacturing, 545 U.S. 308 (2005): the state law claim was necessarily raised, actually disputed, substantial, and capable of resolution in federal court without disrupting the federal-state balance approved by Congress.

 

Nalco Company LLC v. Bonday, Case No. 22-13546 (11th Cir. 2025).

Arbitrators exceed their powers – and their resulting award may be vacated – if they rule on issues never submitted to arbitral panel.

 

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Author

Manny Farach

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