Samson Energy Resources Co. v. Semcrude, L.P., 728 F.3d 314

Four Oklahoma oil-and-gas producers (Appellants) supplied Debtors on credit and asserted retained property interests and liens in Debtors’ oil/gas; they argued claims could not be discharged without an adversary proceeding and sought to pursue proceedings or litigate in an adversary action post-confirmation.
Debtors filed Chapter 11 in July 2008; after a Producer Settlement and plan confirmation in October 2009, the plan discharged claims and required dismissal of related adversary proceedings; Appellants objected to the plan and sought to proceed in the Bankruptcy Court instead.
The plan was incorporated into the reorganization and distributions were set; Appellants did not join the Producer Settlement and did not obtain a stay pending appeal, leading to plan effectiveness and post-confirmation transactions.
The District Court dismissed the appeal as equitably moot based on substantial consummation and lack of a stay; Court of Appeals reverses, concluding the record does not support dismissal on equitable mootness and remands for merits review.
The court adopts a two-step equitable mootness framework (substantial consummation, then potential unraveling/harm) but emphasizes the burden should rest on the party seeking dismissal and that dismissal requires substantial evidentiary support; it concludes the record here does not show that relief would collapse the plan or unduly harm third parties.

Issue	Plaintiff's Argument	Defendant's Argument	Held
Whether the plan’s substantial consummation justifies equitable mootness here.	Appellants contend substantial consummation plus lack of stay justify dismissal.	Debtors argue substantial consummation and reliance on the plan support equitable mootness.	No; the record does not support dismissal on equitable mootness.
Whether granting relief would unravel the plan or harm third parties.	Relief could allow Appellants to pursue claims without destabilizing the Producer Settlement.	Relief would require unraveling the plan and harming third parties relying on finality.	Record insufficient to show unraveling or significant third-party harm.
Who bears the burden to prove dismissal is warranted under equitable mootness.	N/A	Burden should be on the party seeking dismissal.	Burden should rest on the party seeking dismissal; the court did not shift to Appellants.

Continental Airlines, Inc. v. United States, 91 F.3d 553 (3d Cir.1996) (en banc approval of equitable mootness; burden considerations)
Continental Airlines, Inc. v. United States, 203 F.3d 203 (3d Cir.2000) (Continental II; not explicitly allowing dismissal without evidence of reliance)
In re Phila. Newspapers, LLC, 690 F.3d 161 (3d Cir.2012) (equitable mootness analysis and finality considerations)
In re Mansaray-Ruffin, 530 F.3d 230 (3d Cir.2008) (due process right to adversary proceeding may trump finality)
In re Chateaugay Corp., 94 F.3d 776 (2d Cir.1996) (burden shifting discussions in equitable mootness context)
United States v. Espinosa, 559 U.S. 260 (2010) (Supreme Court; adversary proceeding error not vacating plan)
Quackenbush v. Allstate Ins. Co., 517 U.S. 706 (1996) (duty to exercise jurisdiction; finality considerations)