Key takeaways:

• Yesterday, the Supreme Court of the United States ruled that a Chapter 11 plan that provides for the sale of assets free and clear of a creditor’s lien must allow the creditor to “credit bid” at the sale.
• RadLAX Gateway Hotel, LLC v. Amalgamated Bank resolved the circuit split on this issue between the Seventh Circuit, on the one hand, and the Third and Fifth Circuits, on the other.