One recovery is enough
June 2, 2025A 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).