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Volume IX, Issue 10

March 12, 2026

 

In re: Guallini-Indij, Case No. 23-1705 (1st Cir. 2026).

A bankruptcy court's previously vested "related to" jurisdiction over an adversary proceeding does not automatically terminate upon the debtor's Chapter 13 discharge and a court must conduct a case-specific inquiry weighing judicial economy, convenience to the parties, fairness, and comity before concluding it lacks jurisdiction.

 

Perruzzi v. The Campbell Soup Co., Case No. 24-1996 (1st Cir. 2026).

A district court's administrative closure of a case without expressly ruling on a pending motion to compel arbitration constitutes a denial of that motion reviewable under 9 U.S.C. § 16(a)(1)(B). 

 

Bouvet v. Illinois Union Insurance Co. (In re: Aqueous Film-Forming Foams Products Liability Litigation), Case Nos. 25-1139 & 25-1143 (4th Cir. 2026).

An MDL transferee court’s case-management order requiring lead counsel's consent before a party may file a motion cannot override the mandatory stay provision of 9 U.S.C. § 3, and a denial of leave to file a motion to stay pending arbitration based solely on lead counsel's refusal to consent constitutes a refusal of a stay reviewable under 9 U.S.C. § 16(a)(1)(A).

 

Norton Outdoor Advertising, Inc. v. Village of St. Bernard, Case No. 25-3265 (6th Cir. 2026).

Under Ohio's three-part Geiger severability test, an unconstitutional content-based public-service exemption in a municipal billboard ordinance is severable from the remainder of the ordinance, and the surviving content-neutral time, place, and manner restrictions on billboards satisfy intermediate First Amendment scrutiny when justified by significant governmental interests in traffic safety, aesthetics, and property values.

 

HPIL Holding, Inc. v. Zhang, Case No. 25-1595 (6th Cir. 2026).

As distinguished from injuries caused by a state-court judgment itself, the Rooker-Feldman doctrine does not bar a federal lawsuit alleging injuries caused by third-party misconduct during state-court proceedings and does not eliminate federal jurisdiction merely because the federal claims may implicitly undermine the reasoning of a prior state-court order.

 

Talon Diversified Holdings, Inc. v. Forsythe, Case Nos. 24-5516, 24-5517, 24-5911, 24-5918, 24-5920, 24-6314 & 24-6638 (9th Cir. 2026).

Corporate authority to file a voluntary chapter 11 bankruptcy petition on behalf of an entity – while important and mandatory – is not jurisdictional, and a bankruptcy court retains subject-matter jurisdiction over a case even if the individual who filed the petition lacked the requisite authority to do so.

 

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Author

Manny Farach

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