UMB Bank, NA v. Linn Energy, LLC

The Fifth Circuit affirmed the district court's denial of Linn Lender's post-petition default interest and held that a reasonable person would not understand the reference to Linn Lender Claims in Article III.B.3 of the bankruptcy plan and the definition of the term "Linn Lender Claims" in Article I.A.114 to incorporate by reference the post-default interest rates set forth in the proofs of claim and credit agreement. The court held that, given the availability of post-petition default interest was specifically reserved when the Final Cash Collateral Order was entered, and that the bankruptcy plan itself contained an Article entitled "No Postpetition or Default Interest on Claims," failure to make specific mention of "default interest" in Article III.B.3 indicated that the parties intended the omission. View "UMB Bank, NA v. Linn Energy, LLC" on Justia Law