The Fifth Circuit's interpretation in Pro-Snax (i.e., whether an estate attorney seeking compensation must demonstrate a material identifiable benefit from the work performed) , was not supported by either the text of § 330 or sound policy. The proper test that should be applied is whether: "the services were "reasonably likely" to benefit the estate at the time the services were rendered."

The bankruptcy court erred in finding that a debtor did not need to comply with 11 USC 1114 to terminate health and life insurance benefits when the debtor employer could unilaterally terminate those benefits outside of bankruptcy pursuant to a reservation of rights clause.

The plain language of section 1114 indicates that Congress intended to restrict a debtor’s ability to modify or terminate, except through the section 1114 process, any retiree benefits during a Chapter 11 bankruptcy proceeding, regardless of whether the debtor could terminate those benefits outside of bankruptcy.

Simultaneous representation of a debtor corporation and its sole stockholder (also a debtor) is not in and of itself improper. Where: (i) the shareholder was a guarantor of the debtor's secured debt, (ii) the value of the debtor's collateral substantially exceeded the secured debt, (iii) the shareholder never filed a claim against the estate and (iv) the secured creditor never pursued the shareholder on account of the guaranty, there was no actual conflict of interest.

Where the attorney failed to disclose simultaneous representation in her 2014 statement, the error was not material, since the shareholder was also in bankruptcy and both his case, and the corporation's case were handled by the same bankruptcy judge, who was clearly aware of the dual representation.

When a lawsuit that arguably violates the discharge injunction is comprised of multiple causes of action, the court must examine each cause of action individually. The mere presence of one dischargeable claim does not necessarily doom the entire lawsuit. If a cause of action seeks relief that is not a "claim" under bankruptcy law, the cause of action would not be barred by the discharge injunction.

Some of the causes of action here involve unique issues associated with affirmative injunctions requiring compliance with environmental laws. Although almost every equitable decree imposes a cost on the defendant, that does not make all equitable obligations dischargeable in bankruptcy.