Ohio v. Roberds, Inc.

266 B.R. 378, 2001 U.S. Dist. LEXIS 14496, 2001 WL 1077901
CourtDistrict Court, S.D. Ohio
DecidedAugust 13, 2001
DocketC-3-00-434
StatusPublished
Cited by1 cases

This text of 266 B.R. 378 (Ohio v. Roberds, Inc.) is published on Counsel Stack Legal Research, covering District Court, S.D. Ohio primary law. Counsel Stack provides free access to over 12 million legal documents including statutes, case law, regulations, and constitutions.

Bluebook
Ohio v. Roberds, Inc., 266 B.R. 378, 2001 U.S. Dist. LEXIS 14496, 2001 WL 1077901 (S.D. Ohio 2001).

Opinion

DECISION AND ENTRY SUSTAINING MOTION TO DISMISS APPEAL (DOC. # 5) FILED BY APPELLEE ROBERDS, INC.; JUDGMENT TO BE ENTERED IN FAVOR OF AP-PELLEE ROBERDS, INC., AND AGAINST APPELLANT STATE OF OHIO; TERMINATION ENTRY.

RICE, Chief Judge.

The State of Ohio appeals from an order of the U.S. Bankruptcy Court for the *379 Southern District of Ohio, Western Division, authorizing the augmentation of the Appellee’s inventory as part of an asset liquidation. Pending before the Court is the Appellee’s Motion to Dismiss the appeal, as moot (Doc. # 5).

I. Factual Background

On January 19, 2000, Appellee Roberds, Inc. (“Roberds”), commenced reorganization under Chapter 11 of the Bankruptcy Code and chose to close nine of its stores, including one in Cincinnati, Ohio, through going-out-of-business sales. Roberds later decided to liquidate the inventory in all of its stores, including six in Ohio. As a result, on May 2, 2000, it filed a motion in the Bankruptcy Court, seeking permission to conduct a complete liquidation of all inventory and other assets. The State objected to the proposed liquidation on the basis that it violated Ohio law. Over the State’s objection, the Bankruptcy Court approved the liquidation sale. The Bankruptcy Court also overruled a motion by the State to stay the sale. On July 21, 2000, the State filed a notice of appeal. (Doc. # 1 at Exh. 18). A third-party liquidator completed the sale on September 17, 2000. Roberds filed its pending Motion to Dismiss on September 28, 2000, arguing that the completed liquidation sale has rendered the present appeal moot. As a result, it seeks dismissal of the appeal. (Doc. # 5).

II. Analysis

Roberds’ Motion to Dismiss implicates the so-called bankruptcy “mootness rule,” codified at 11 U.S.C. § 363(m), which provides:

The reversal or modification on appeal of an authorization under subsection (b) or (c) of this section of a sale or lease of property does not affect the validity of a sale or lease under such authorization to an entity that purchased or leased such property in good faith, whether or not such entity knew of the pendency of the appeal, unless such authorization and such sale or lease were stayed pending appeal.

Although the foregoing provision does not expressly state that an appeal following a completed bankruptcy sale is moot, it has been interpreted in such a manner. The Second Circuit explained the operation of § 363(m) in In re Gucci, 105 F.3d 837 (2nd Cir.1997), as follows:

... Though this provision in terms states only that an appellate court may not “affect the validity” of a sale of property to a good faith purchaser pursuant to an unstayed authorization, and can even be read to imply that an appeal from an unstayed order may proceed for purposes other than affecting validity of the sale, courts have regularly ruled that the appeal is moot. As one court reasoned, the appeal is moot because “the court has no remedy that it can fashion even if it would have determined the issues differently.” Thus, regardless of the merit of an appellant’s challenge to a sale order, we may neither reverse nor modify the judicially-authorized sale if the entity that purchased or leased the property did so in good faith and if no stay was granted.
We have recognized that a rule limiting appellate jurisdiction over unstayed sale orders to the issue of good faith furthers the policy of finality in bankruptcy sales, and assists the bankruptcy court to secure the best price for the debtor’s assets. ’This limitation of the issues on appeal generally is warranted where an appellant did not seek a stay pending appeal, and reflects the view that an appellant is rightly burdened with the risks associated with challenging a sale authorization when that appel *380 lant did not first seek to stay the sale[.] The limitation also recognizes that this Court may be powerless to undo or rewrite the terms of the consummated sale.
Yet even where an appellant timely moves to stay a judicially-authorized sale, a district court’s denial of that motion will similarly limit the issues on appeal. Although an appellant’s challenge to a sale authorization might raise meritorious arguments, a district court’s denial of a requested stay has the effect of precluding this Court from reviewing those issues, other than the good faith of the purchaser, if the sale has closed in the interim.

Id. at 839-40 (citations and footnote omitted).

The Sixth Circuit also has recognized that § 363(m) renders a bankruptcy appeal moot once a sale has been completed. See In re 255 Park Plaza Assoc. Ltd. Partnership, 100 F.3d 1214, 1216 (6th Cir.1996) (“Bankruptcy’s mootness rule applies when an appellant has failed to obtain a stay from an order that permits a sale of a debtor’s assets. The bankruptcy mootness rule differs from general mootness law because it is based on ‘the general rule that the occurrence of events which prevent an appellate court from granting effective relief renders an appeal moot, and the particular need for finality in orders regarding stays in bankruptcy.’ ”) (citations omitted).

In the present case, the State sought a stay from the Bankruptcy Court, but the request was denied. The State neither appealed that decision nor moved for a stay in this Court, as it could have done under Bankruptcy Rule 8005. Notably, the State does not dispute the good faith of the entity that purchased Roberds’ assets. 1 As a result, Roberds argues that the present appeal should be dismissed, as moot. (Doc. # 5 at 12-14). In opposition to the foregoing conclusion, the State argues that its appeal involves issues that are capable of repetition and evading review. 2 In particular, the State reasons that “while the going out of business sale involving Appellee Roberds may have been completed, the issue of whether state law permits augmentation of inventory by third-parties conducting such sales remains to be resolved by appellate review.” 3 (Doc. # 7 at 3).

Upon review, the Court finds the State’s argument to be unpersuasive. When determining whether an issue is capable of repetition and evading review, the Court must consider whether: (1) the duration of the challenged action is too short to be litigated before its cessation or expiration; and (2) there is a reasonable ex *381 pectation that the complaining party will be subjected to the same action again. Murphy v. Hunt, 455 U.S. 478, 482, 102 S.Ct. 1181, 71 L.Ed.2d 353 (1982). In the present case, the Court does not dispute that bankruptcy sales often proceed on an expedited basis. Nor does it dispute that the State’s legal argument likely will arise again in future bankruptcy actions.

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Cite This Page — Counsel Stack

Bluebook (online)
266 B.R. 378, 2001 U.S. Dist. LEXIS 14496, 2001 WL 1077901, Counsel Stack Legal Research, https://law.counselstack.com/opinion/ohio-v-roberds-inc-ohsd-2001.