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The United Savings Association of Texas v. Timbers of Inwood Forest Associates, Ltd., 1987 case revolved around the interpretation of a provision in the Bankruptcy Code concerning adequate protection for creditors' interests during bankruptcy proceedings. The Supreme Court ruled that an undersecured creditor (a lender whose collateral is worth less than their claim) was not entitled to compensation for delay damages - i.e., interest on its secured claim or any decrease in value of its collateral during a stay pending reorganization under Chapter 11 bankruptcy laws. This decision clarified how "adequate protection" should be interpreted and applied within the context of U.S. bankruptcy law, establishing that it does not extend to protect potential appreciation or profits lost due to delays caused by automatic stays.
In the dissenting opinion for United Savings Association of Texas v. Timbers of Inwood Forest Associates, Ltd., Justice Blackmun argued that the majority's interpretation was contrary to both the language and purpose of Bankruptcy Code § 362(d)(1). He contended that an undersecured creditor should be entitled to compensation for delay in foreclosure caused by an automatic stay in bankruptcy proceedings. According to him, this is because such a delay could result in depreciation or loss of value on their collateral property over time. The majority’s decision not allowing these creditors additional protection would discourage lending practices and negatively impact future borrowers as lenders might become more cautious due to potential losses during bankruptcy stays. Thus, he believed that adequate protection should include protecting a secured creditor from decrease in value of its interest while it is stayed from foreclosing on its security interest.