Barbra Parlin

In keeping with the past five years, 2025 has continued to be an active time for airline restructurings and liquidations. The two largest U.S. aviation Chapter 11 proceedings that commenced during 2024, Spirit Airlines and GOL, both concluded during the first half of 2025 by successfully confirming a Chapter 11 plan of reorganization. While GOL has thrived since exiting Chapter 11, Spirit Airlines filed a second Chapter 11 case (commonly referred to as a "Chapter 22") only a few months later.

In In re Pack Liquidating, LLC (Pack Liquidating), the U.S. Bankruptcy Court for the District of Delaware held that bankruptcy courts have authority to grant creditors' committees derivative standing to assert claims belonging to the estate in cases involving debtors that are limited liability companies (LLCs). Federal law gives bankruptcy courts the authority to grant a creditors' committee derivative standing.