Earlier this month, I submitted a post looking at an Opinion in the Eclipse Aviation bankruptcy. In the Eclipse Opinion, Judge Walrath discussed the subject matter jurisdiction of the Bankruptcy Court. Specifically, the Court looked at whether certain claims brought by a plaintiff fell within the Court's "related to" jurisdiction. My prior post regarding the Eclipse decision is available here.

In my prior post, I mentioned that the Eclipse decision was worth review, in part, because the issue of subject matter jurisdiction comes up less frequently than issues such as relief from stay or plan confirmation. Days later, Judge Walsh issued a decision in the Factory 2-U bankruptcy concerning a motion to dismiss a complaint for lack of subject matter jurisdiction. Perhaps, then, the issue of the Court's subject matter jurisdiction is more common than I initially suggested. Judge Walsh's decision in Eclipse is available here for review.