Ryniker v. Sumec Textile Co., Case No. 24-2090 (2d Cir. 2026).
An overseas creditor that authorizes a collection insurer and its subagent to file a proof of claim and “do all that is appropriate” to collect the full amount of the debt implicitly grants those agents actual authority to accept service of process in a bankruptcy adversary proceeding seeking to reduce that recovery, making service on the subagent effective under Bankruptcy Rule 7004(b)(3).
Halbower v. Hiscox Syndicate 33 of Lloyd’s of London, Case No. 25-1152 (6th Cir. 2026). For diversity jurisdiction under 28 U.S.C. § 1332(a)(2), a Lloyd’s of London syndicate sued or sued upon as the underwriting “Syndicate” is treated as an unincorporated association whose citizenship is that of each underwriting “Name,” i.e., the parties comprising the syndicate, so a court must determine the citizenship of all Names rather than relying on the citizenship of syndicate’s managing agent or other market actors.
Reinhardt v. Prince, Case No. 25-1072 (6th Cir. 2026).
A tax foreclosure that vests title in the county shortly before a debtor’s bankruptcy petition can be avoided as a preferential transfer under 11 U.S.C. § 547(b) when, considering the statutorily required post‑foreclosure sale process, the transfer enables an oversecured tax creditor to receive more – including a statutory sales commission – than the creditor would receive on its secured claim in a hypothetical Chapter 7 liquidation.
Declan Flight, Inc. v. Textron eAviation, Inc., Case No. 24-10913 (11th Cir. 2026).
Federal common law, including whether dismissal for forum non conveniens is appropriate, governs after it is determined that a forum-selection clause is valid and enforceable.
