Executory Contracts/Leases

Sixth Circuit Panel Splits on the Attributes of a ‘Governmental Unit’

Sixth Circuit narrowly rules that a community health service is not a governmental unit and is thus eligible for chapter 11.
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Covenant Not to Compete Survives a Chapter 7 Discharge, Judge Nugent Says

Breaching a covenant not to compete does not give rise to a claim, because the primary remedy is equitable.

Profit Sharings in Leases Are Unenforceable Anti-Assignments, Third Circuit Says

Third Circuit upholds Delaware’s Judge Gross by nixing profit-sharing agreements under Section 365(f)(1).

Terminating a Lease for Default Doesn’t Invoke the § 362(b)(10) Stay Exception

Lower courts are split on whether terminating a nonresidential lease for default means there is no automatic stay.

Assuming a Lease Under Section 365(p) Doesn’t Also Require Reaffirmation, Some Say

Courts are split on the interpretation of BAPCPA’s treatment of automatically rejected leases in chapter 7.

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