Problems in the Code: Solving the Ruti-Sweetwater Problem

December 4, 2025

Cleary Gottlieb partner Luke Barefoot, senior attorney David Schwartz, and associate Jack Massey co-authored the article, “Problem in the Code: Solving the Ruti-Sweetwater Problem,” published by the American Bankruptcy Institute.

Luke, David, and Jack discuss a long-running gap in the Bankruptcy Code regarding how courts should handle creditor classes that don’t vote on reorganization plans and provide their recommendation for resolving the issue.

Read the article.