In re: Structure Ace, LLC

United States Bankruptcy Court, E.D. Louisiana·Decided September 17, 2026·No. 25-11911·Unknown

Opinion

UNITED STATES BANKRUPTCY COURT EASTERN DISTRICT OF LOUISIANA

IN RE: § CASE NO: 25-11911 § STRUCTURE ACE, LLC, § CHAPTER 7 § DEBTOR. § SECTION A

MEMORANDUM OPINION AND ORDER

Before the Court are cross-motions for summary judgment: (i) the Motion for Summary Judgment (the “Purchasers’ MSJ”), [ECF Doc. 168], filed by Property Claim Relief, LLC (“PCR”), Insured Advocacy Group, LLC (“IAG”), and Insured Advocacy Group II, LLC (“IAG 2”) (collectively, the “Purchasers”); and (ii) the Trustee’s Motion for Summary Judgment Against Property Claim Relief, LLC (the “Trustee’s MSJ”), [ECF Doc. 169], filed by Greta M. Brouphy, the appointed Chapter 7 Trustee (the “Trustee”). Both motions are opposed. [ECF Docs. 171 & 172]. Both parties submitted statements of uncontested material facts, [ECF Docs. 168-1 & 169-1],1 as well as reply briefs in support of their respective motions for summary judgment, [ECF Docs. 174 & 175]. Also before the Court is the Trustee’s objection to PCR’s proof claim (the “Claim Objection”). [ECF Doc. 121]. For the reasons set forth below, the Court GRANTS IN PART and DENIES IN PART the Purchasers’ MSJ; GRANTS IN PART and DENIES IN PART the Trustee’s MSJ; and SUSTAINS IN PART and OVERRULES IN PART the Claim Objection.

1 The Purchasers filed a response to the Trustee’s statement of uncontested material facts. [ECF Doc. 172-1]. The Trustee’s opposition to the Purchasers’ MSJ includes an objection to a number of statements in the Claimants’ statement of facts as constituting legal conclusions and/or as unsupported. [ECF Doc. 171]. JURISDICTION AND VENUE This Court has jurisdiction to grant the relief provided for herein pursuant to 28 U.S.C. § 1334. The matters presently before the Court constitute core proceedings that this Court may hear and determine on a final basis under 28 U.S.C. § 157(b)(2)(B). Venue is proper pursuant to 28 U.S.C. §§ 1408 and 1409.

PROCEDURAL HISTORY In the aftermath of Hurricane Ida in October 2021, the Debtor contracted with a number of property owners to repair property damage caused by the storm. In connection with the repair contracts, each property owner entered into an agreement purporting to, among other things, assign its post-loss insurance benefits to the Debtor. On August 22, 2022, and May 12, 2023, the Debtor entered into master purchase agreements with IAG and PCR, respectively, to provide for the sale and assignment of the Debtor’s rights under the repair contracts as well as the proceeds payable under the property owners’ insurance policies. Pursuant to the master purchase agreements, the Debtor executed purchase addenda with each Purchaser evidencing the sale of specific portfolios

of invoices. Each purchase addendum provides that the Purchaser has the right to disburse to itself all funds received under that portfolio until it has recovered the purchase price of the portfolio plus a factor fee, before remitting any surplus to the Debtor. On August 28, 2025, the Debtor filed a voluntary petition for bankruptcy relief under Subchapter V of Chapter 11 of the Bankruptcy Code. [ECF Doc. 1]. Each of the Purchasers filed a proof of claim. [Claim Nos. 17–19]. On December 1, 2025, the Court entered an Order converting the case to one under Chapter 7. [ECF Doc. 61]. Greta Brouphy was appointed to serve as the Chapter 7 Trustee. [ECF Doc. 66]. The Court scheduled an evidentiary hearing on September 10, 2026, [ECF Docs. 130 & 139], to resolve several contested matters related to the respective rights of the Debtor and the Purchasers under the master purchase agreements and purchase addenda (together, the “Contested Matters”): First, on March 25, 2026, PCR filed a motion to lift the stay to exercise its rights of recovery

under claims it alleges it purchased related to work performed by the Debtor for the 1750 St. Charles Avenue Homeowners’ Association (the “Lift-Stay Motion”). [ECF Doc. 115]. At the hearing on the Lift-Stay Motion, the Trustee stipulated that the purchase agreement with PCR constituted a true sale of the Debtor’s accounts receivable related to that particular project. [ECF Doc. 124]. The Court entered an Order granting in part the Lift-Stay Motion and scheduling an evidentiary hearing to hear evidence on issues relating to the allocation of payments. [ECF Doc. 130]. Second, on April 13, 2026, the Trustee filed an objection to PCR’s proof of claim (the “Claim Objection”). [ECF Doc. 121].2 PCR’s proof of claim asserts a secured claim in the amount

of $13,379,373.51 for “Breach of Contracts/Purchase of Accounts” under its master purchase agreement and purchase addenda with the Debtor. [Claim No. 19-1]. The Claim Objection argues that PCR has no claim against the estate because, to the extent that PCR’s master purchase agreement and purchase addenda are valid at all,3 they constituted true sales without recourse. Finally, April 24, 2026, and May 13, 2026, the Trustee filed motions to compromise claims (“9019 Motions”) against two of the Debtor’s customers: Historic St. Peter African Methodist

2 The Trustee has yet to object to the proofs of claim filed by IAG and IAG 2. [Claim Nos. 17-1 and 18-1]. 3 The Claim Objection asserts that PCR had not proven that the sales were valid because PCR had not yet produced the insurance assignment agreements executed by the Debtor’s customers. Church (“Saint Peter”) and Greater Allen Chapel of A.M.E. Church (“Greater Allen”). [ECF Docs. 125 & 132]. The Purchasers filed oppositions to the 9019 Motions, asserting that the Debtor had sold its invoices relating to Saint Peter and Greater Allen to PCR and IAG 2, respectively, under the master purchase agreements and purchase addenda and that the Trustee lacks the authority to settle non-estate claims. [ECF Docs. 134 & 144].

The parties filed the instant motions for summary judgment pursuant to the Court’s Scheduling Orders. In sum, the Purchasers’ MSJ asks the Court to find that, pursuant to the master purchase agreements and purchase addenda: (1) the Purchasers are the owners of the Debtor’s invoices and of any claim arising therefrom, with exclusive authority to pursue collection, (2) the Purchasers are the owners of insurance benefits that were assigned to the Debtor prior to August 1, 2023, (3) the invalidity of any insurance assignment does not affect the Purchasers’ other rights under the master purchase agreements, and (4) the Trustee is not entitled to any distribution on account of the purchased invoices until the Purchasers have collected all amounts they are entitled to across all portfolios.

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In re: Structure Ace, LLC, (La. 2026).

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