U. S. Bank N. A. v. Village at Lakeridge, LLC, 138 S. Ct. 960

Village at Lakeridge, LLC (debtor) filed Chapter 11; principal creditors: U.S. Bank (~$10M) and owner MBP Equity Partners ($2.76M).
A cramdown plan under 11 U.S.C. §1129(b) requires at least one impaired class to accept the plan, excluding any acceptance by an "insider" (§1129(a)(10)); the Code lists certain statutory insiders and permits courts to recognize additional non‑statutory insiders.
MBP, a statutory insider (owner), could not consent for cramdown; MBP’s board member Kathleen Bartlett offered MBP’s claim to Robert Rabkin for $5,000; Rabkin purchased it and voted to accept the plan.
U.S. Bank challenged Rabkin as a non‑statutory insider, arguing the purchase was not at arm’s length (Rabkin had a romantic relationship with Bartlett and the sale was not widely solicited).
Bankruptcy Court found Rabkin’s purchase was an arm’s‑length, speculative investment; Ninth Circuit affirmed, applying clear‑error review to the Bankruptcy Court’s factual determination.
Supreme Court granted certiorari limited to the standard of appellate review for whether a transaction was arm’s length in determining non‑statutory insider status.

Issue	U.S. Bank (Petitioner)	Lakeridge (Respondent) & U.S. Govt (amicus)	Held
What standard of appellate review governs a bankruptcy court’s determination that a transferee is a non‑statutory insider because the transaction was (or was not) arm’s length?	Mixed question should be reviewed de novo because applying the broad legal standard requires developing legal norms.	Review for clear error because the question is primarily factual—weighing credibility and record‑bound facts—so defer to the trial court.	Clear‑error review applies: the arm’s‑length inquiry is a fact‑intensive mixed question best left to the bankruptcy court, subject to deferential review.

United States v. Detroit Timber & Lumber Co., 200 U.S. 321 (syllabus not part of opinion) (explaining syllabi are prepared by Reporter of Decisions)
Highmark Inc. v. Allcare Health Mgmt. Sys., 572 U.S. 559 (appellate review of legal conclusions is de novo)
Thompson v. Keohane, 516 U.S. 99 (mixed questions and basic factual findings)
Pullman‑Standard v. Swint, 456 U.S. 273 (definition of mixed question of law and fact)
Miller v. Fenton, 474 U.S. 104 (standard-of-review depends on which judicial actor is better positioned)
Anderson v. Bessemer City, 470 U.S. 564 (deference to trial court on factfinding)
Commissioner v. Duberstein, 363 U.S. 278 (clear‑error review for factual inferences from undisputed facts)
Salve Regina Coll. v. Russell, 499 U.S. 225 (appellate courts’ institutional advantage on legal issues)
Pierce v. Underwood, 487 U.S. 552 (recognizing fact‑intensive inquiries resist generalization)