In March, we reported on the Fourth Circuit’s 2-1 decision in Goldman Sachs Bank USA v. Brown, No. 25-1439, affirming a bankruptcy court’s refusal to compel arbitration of debtors’ claims for willful violation of the automatic stay under Section 362(k). Goldman Sachs has now sought further review, filing a petition for a writ of certiorari with the United States Supreme Court on June 16, 2026.
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