After confirmation of a plan, the ability of the debtor to enforce a claim once held by the estate is limited to that which has been retained in the plan. A plan may provide for the retention and enforcement of any claim by the debtor. For a debtor to preserve a claim, the plan must expressly retain the right to pursue such actions. The reservation must be specific and unequivocal. If a debtor has not made an effective reservation, the debtor has no standing to pursue a claim that the estate owned before it was dissolved.

The disclosure statement can be considered by a court in assessing whether there has been an effective retention of a claim. A plan need not specifically identify each potential defendant to preserve claims. A reservation of "preference claims" may be adequate.

"Bankruptcy judges are awfully busy; they shouldn't be bothered with resolving claims that bear only remotely on the bankruptcy proceeding."

Although the issue of whether bankruptcy courts have supplemental jurisdiction need not be decided in this case, the court notes the oddity that cases that permit bankruptcy judges to exercise supplemental jurisdiction allow bankruptcy courts to make and not just recommend the decision resolving the supplemental claim. This is inconsistent with the statutory treatment of "related to" jurisdiction (and why should supplemental jurisdiction be broader?) and is in tension with the Supreme Court's reluctance to allow bankruptcy judges dispositive authority over state-law claims. citing Stern v. Marshall