The U.S. Court of Appeals for the Ninth Circuit recently held in Blixseth v. Brown (In re Yellowstone Mountain Club, LLC
Expansion of the <i>Barton</i> Doctrine To Unsecured Creditors' Committees
The U.S. Court of Appeals for the Ninth Circuit recently held in <i>Blixseth v. Brown</i> that under <i>Barton v. Barbour</i>, a plaintiff must obtain a bankruptcy court's permission before commencing a lawsuit in another forum against a member of the committee of unsecured creditors, and that <i>Stern v. Marshall</i> does not preclude bankruptcy courts from adjudicating such claims on the merits.

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