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Highland Capital Management, L.P. v. NexPoint Advisors, L.P., et al.

Paid petition · United States Court of Appeals for the Fifth Circuit, No. 21-10449 · judgment September 7, 2022


Certiorari denied · July 2, 2024
Pre-decision estimate: 4% cert probability

Before the decision, roughly the 4.1% base rate. The model weighted this up for a Fifth Circuit decision below, a circuit split argued in the petition, and a business petitioner, and down for a business respondent.

Question presented

Section 524(e) of the Bankruptcy Code states that the “discharge of a debt of the debtor does not affect the liability of any other entity on, or the property of any other entity for, such debt.” According to the Fifth Circuit, even though the text refers to the effect of a discharge rather than to the powers of a bankruptcy court, section 524(e) “categorically bars” a court from confirming any chapter 11 plan of reorganization that releases third parties from liability, either in full or through their limited exculpation for negligence claims relating to the administration of the bankruptcy estate as in this case. In the opinion below, the Fifth Circuit acknowledged that, by contrast, the Second, Third, Fourth, Sixth, Seventh, Ninth, and Eleventh Circuits “read[] § 524(e) to allow varying degrees of limited third-party exculpations.” The question presented is whether section 524(e), as its text suggests, states only the effect of a discharge on third parties’ liability for a debtor’s own debts or instead, as the Fifth Circuit holds, constrains the power of a court when confirming a plan of reorganization. (i)

Counsel of record

For petitioner
Roy T. Englert Jr.
Kramer Levin Naftalis & Frankel LLP

For respondent
Douglas S. Draper
Heller Draper & Horn, LLC

Case

Conference history
Distributed for 5 conferences

Amicus briefs
1 cert-stage

Related
Vide, 22-669

Linked docket
22A397

Proceedings

  1. Jul 02 2024
    Petition DENIED.
  2. Jun 28 2024
    DISTRIBUTED for Conference of 7/1/2024.
  3. Jun 28 2024
    Supplemental brief of petitioner Highland Capital Management, L.P. filed.
  4. Jun 28 2024
    Supplemental brief of respondents NexPoint Advisors, L.P., et al. filed. VIDED.
  5. Dec 01 2023
    Rescheduled.
  6. Dec 01 2023
    DISTRIBUTED for Conference of 12/8/2023.
  7. Nov 08 2023
    DISTRIBUTED for Conference of 12/1/2023.
  8. Nov 06 2023
    Supplemental brief of respondents NexPoint Advisors, L.P., et al. filed. VIDED. (Distributed)
  9. Oct 19 2023
    Brief amicus curiae of United States filed. VIDED.
  10. May 15 2023
    The Solicitor General is invited to file a brief in this case expressing the views of the United States.
  11. Apr 25 2023
    DISTRIBUTED for Conference of 5/11/2023.
  12. Apr 21 2023
    Waiver of the 14-day waiting period for the distribution of the petition pursuant to Rule 15.5 filed by petitioner.
  13. Apr 19 2023
    Response to petition from respondents The Dugaboy Investment Trust and Get Good Trust filed. VIDED.
  14. Apr 11 2023
    Letter dated April 11, 2023 from counsel for respondents Highland Income Fund, et al. filed.
  15. Mar 20 2023
    Response Requested. (Due April 19, 2023)
  16. Mar 08 2023
    DISTRIBUTED for Conference of 3/24/2023.
  17. Feb 10 2023
    Brief of respondent NexPoint Advisors, L.P., et al. filed.
  18. Feb 06 2023
    Waiver of right of respondents Highland Income Fund; NexPoint Strategic Opportunities Fund; Highland Global Allocation Fund; and NexPoint Capital, Inc. to respond filed.
  19. Feb 06 2023
    Motion to extend the time to file a response is granted and the time is extended to and including February 15, 2023.
  20. Feb 06 2023
    Waiver of right of respondent The Dugaboy Investment Trust to respond filed.
  21. Feb 03 2023
    Motion to extend the time to file a response from February 8, 2023 to February 15, 2023, submitted to The Clerk.
  22. Jan 05 2023
    Petition for a writ of certiorari filed. (Response due February 8, 2023)
  23. Nov 08 2022
    Application (22A397) granted by Justice Alito extending the time to file until January 5, 2023.
  24. Nov 03 2022
    Application (22A397) to extend the time to file a petition for a writ of certiorari from December 6, 2022 to January 5, 2023, submitted to Justice Alito.