A complicated bankruptcy proceeding led to a straightforward holding: “Courts cannot award value under Section 550(a) [the preferential-transfer statute] when the estate has recovered its transferred property in kind” elsewhere in the plan. Ad Hoc Group of Senior Secured Noteholders v Del. Trust Co. (In re Sanchez Energy Corp.), No. 23-20557 (May 30, 2025).

In Carter v. Local 556, the Fifth Circuit reversed (among other matters) a contempt order that required a party’s counsel to attend “religious liberty training,” reasoning:

Courts are tasked with resolving limited questions and administering justice to the parties before them. United States v. Texas, 599 U.S. 670, 693–94 (2023) (Gorsuch, J., concurring) (“This tracks the founding-era understanding that courts render a judgment or decree upon the rights of the litigants . . . [and] ensures that federal courts respect the limits of their Article III authority to decide cases and controversies ….” (citations omitted) (cleaned up)). But when a court’s contempt sanction in a civil matter is both overbroad in scope and undoubtedly punitive in nature, the judiciary risks appearing contemptuous like the contemnor. In this civil case, the sanction plainly exceeded remedial bounds and sought to punish Southwest’s attorneys through a directive that did little to coerce the airline’s compliance with the district court’s judgment.

No. 23-10536 (May 8, 2025).