Pryor v. Rosenblatt, 2:24-cv-07895

The bankruptcy case was initiated by Stain-Less, Inc. (a dry-cleaning business) filing for Chapter 11, which later converted to Chapter 7.
David Rosenblatt, the owner, transferred business assets to DHR Processing Inc. (another defendant) shortly before bankruptcy, with no consideration paid and after a judgment was obtained by Marzak Realty Associates (a creditor).
EPA (holding a $6.9 million claim for hazardous contamination) and Marzak (a $448,000 creditor) objected to a proposed $100,000 settlement between the Trustee and Rosenblatt/DHR, arguing it was inadequate and unfair.
The Bankruptcy Judge denied settlement approval, citing likely litigation success and overwhelming creditor objections, specifically finding the settlement neither fair nor equitable under the Iridium factors.
The Trustee appealed the denial to district court, arguing for jurisdiction either as a final order, under the collateral order doctrine, or by interlocutory appeal.
The district court dismissed the appeal for lack of jurisdiction, holding the order denying settlement was neither final nor otherwise appealable at this stage.

Issue	Plaintiff's Argument	Defendant's Argument	Held
Is a denial of bankruptcy settlement approval a final, appealable order?	Pryor: Yes—denies relief, ends dispute re: that settlement.	EPA/Marzak: No—litigation continues, no right finally decided.	Not final—litigation continues, not appealable.
Does the collateral order doctrine permit appeal here?	Pryor: Yes—important, unreviewable question separate from merits.	EPA/Marzak: No—decision entwined with merits, reviewable after completion.	No—order is not separate from merits, not unreviewable.
Should district court grant leave for interlocutory appeal?	Pryor: Yes—presents controlling question of law (Iridium factors) advancing litigation.	EPA/Marzak: No—requires factual/record analysis, not a pure legal issue.	No—no pure legal question suitable for interlocutory appeal.
Can the Trustee's intention to abandon the case create appellate jurisdiction/finality?	Pryor: Might end case if denied—so it is final.	EPA/Marzak: Trustee's future actions do not affect jurisdiction.	Trustee cannot manufacture finality through conditional abandonment.

Ritzen Grp., Inc. v. Jackson Masonry, LLC, 589 U.S. 35 (defines finality in bankruptcy orders as those that definitively dispose of discrete disputes)
Bullard v. Blue Hills Bank, 575 U.S. 496 (order denying plan confirmation is not final if debtor can propose another plan)
In re Iridium Operating LLC, 478 F.3d 452 (sets forth factors bankruptcy courts use to evaluate settlements)
Steel Co. v. Citizens for a Better Env't, 523 U.S. 83 (federal courts must establish jurisdiction before addressing merits)
In re Quigley Co., Inc., 676 F.3d 45 (finality in bankruptcy differs from ordinary civil litigation)