New Cases For the Week of March 17, 2003

Citicorp Venture Capital, Ltd. v. Committee of Creditors Holding Unsecured Claims (DBN Subscription Required)	3rd Cir.	The "American Rule" should not be applied to the subordination of the administrative and professional costs. When facts warrant equitable subordination of an insider creditor's claim on account of undue delay caused by such creditor and the correlative increase in professional fees suffered by the estate due to such delays, quantifying the amount of subordination by reference to the amount of increased professional fees does not offend the "American Rule" against fee shifting.
In re Bouchie (DBN Subscription Required)	5th Cir.	The bankruptcy court did not err in finding that a debtor's property was rural homestead because it was not served by at least three of the municipal services listed in Tex. Prop. Code 41.002(c). The legislature's amendments to the homestead law precluded use of an older common law multi-factor test to assess the rural character of the homestead.
In re Kujawa (DBN Subscription Required)	8th Cir.	An order compelling post-judgment discovery in aid of collection is not a final order subject to appellate review. To obtain appellate review of such discovery, the judgment creditor must disobey the order and subject himself to contempt sanctions, which are the proper subject of appellate review.