Tran v. Citizens Bank, N.A. (In re: Tran), Case No. 24-1101 (1st Cir. 2025).
Even when the foreclosure deed itself is defectively recorded, Massachusetts law establishes that a properly recorded affidavit of sale can provide sufficient constructive notice of a foreclosure sale to defeat a bankruptcy trustee's 11 U.S.C. § 544 avoidance powers.
Molecular Dynamics, Ltd. v. Spectrum Dynamics Medical Limited, Case Docket No. 24-2209-cv (2nd Cir. 2025).
Vacatur actions of foreign arbitral awards do not "fall under" the New York Convention and the Federal Arbitration Act as required by 9 U.S.C. § 203 for federal jurisdiction, and accordingly, district courts lack subject-matter jurisdiction to hear petitions to vacate these awards.
Lamonaco v. Experian Information Solutions, Inc., Case No. 24-11270 (11th Cir. 2025).
An arbitration agreement may delegate threshold arbitration questions, including the question of whether party waived the right to arbitrate, to the arbitral panel.
