Church Joint Venture, L.P. v. Blasingame (In Re Blasingame), 651 F. App'x 386

Benard and Margaret Blasingame filed bankruptcy in 2008 but omitted millions in assets held through trusts, companies, and clearing accounts.
Trustee and creditors suspected concealment and the bankruptcy court found evidence of badges of fraud; lawyers Grusin and Fullen provided suspect pre-petition advice and valuation choices.
Trustee lacked resources to pursue malpractice claims; Church Joint Venture (major creditor) was authorized to sue Grusin and Fullen on the estate's behalf.
Trustee and the Blasingames twice moved under Fed. R. Bankr. P. 9019 to settle the malpractice claim (first for $1M, then $1.25M); Church objected as holder of 95% of unsecured claims.
Bankruptcy court denied approval, concluding malpractice evidence was strong and that Church was best positioned to evaluate settlement value.
Blasingames appealed; the BAP dismissed for lack of jurisdiction. The Sixth Circuit (panel) likewise dismisses for want of jurisdiction.

Issue	Blasingames' Argument	Church/Trustee/Respondent Argument	Held
Whether Sixth Circuit has jurisdiction under 28 U.S.C. § 158(d)(1) to hear appeal of bankruptcy court's denial of settlement approval	Denial of settlement was final because approval would have ended the malpractice litigation	Order was not final; trustee can propose other settlements or pursue litigation so rights remain unsettled	Dismissed for lack of jurisdiction; order not final
Whether the collateral order doctrine permits immediate appeal	Denial is effectively final when grant would terminate the underlying suit	Collateral-order doctrine applies only to orders that finally determine claims of right; this denial did not	Collateral-order doctrine does not apply
Applicability of finality principles for discrete disputes within a larger bankruptcy case	Finality exists because settlement would conclude the adversary proceeding	Finality lacking when order leaves parties' rights and obligations unresolved	Order nonfinal under Howard Delivery/Bullard framework
Whether denial altered status quo or fixed parties' rights regarding malpractice claim	Approval would have concluded the claim, so denial is reviewable	Denial changed nothing — trustee may continue, refile, or seek approval later	Denial did not alter status quo; not appealable as of right

Howard Delivery Serv. v. Zurich Am. Ins. Co., 547 U.S. 651 (2006) (orders appealable as of right must finally dispose of discrete disputes within the larger bankruptcy case)
Bullard v. Blue Hills Bank, 135 S. Ct. 1686 (2015) (denials that leave parties free to alter filings are nonfinal and not appealable as of right)
In re Julien Co., 146 F.3d 420 (6th Cir. 1998) (§ 158(d)(1) jurisdiction limited to final bankruptcy-court decisions)
Cohen v. Beneficial Indus. Loan Corp., 337 U.S. 541 (1949) (establishing the collateral order doctrine)
In re Dow Corning Corp., 86 F.3d 482 (6th Cir. 1996) (collateral order doctrine applies only to orders that finally determine claims of right)