context: It remains an open question of law, at least in the First Circuit, whether there is related-to jurisdiction over a case against a non-debtor, third-party defendant who has a potential (as opposed to an actual) claim for contribution or indemnity against the debtor.
citation_a.signal: see
citation_a.parenthetical: noting that "[t]he First Circuit has not yet addressed the appropriate standard to be applied in evaluating whether contractual indemnification obligations give rise to 'related to' bankruptcy jurisdiction."
citation_a.sentence: See Cambridge Place, 2010 WL 6580503, 2010 U.S. Dist. LEXIS 142954 (noting that “[t]he First Circuit has not yet addressed the appropriate standard to be applied in evaluating whether contractual indemnification obligations give rise to ‘related to’ bankruptcy jurisdiction.”); see also In re Santa Clara County Care Consortium, 223 B.R. 40 (1st Cir. BAP 1998) (“[T]he determination of whether a removed state court proceeding is sufficiently related to a debtor’s bankruptcy to confer subject matter jurisdiction is complicated by what appears to be contradictory opinions.”).
citation_b.signal: see also
citation_b.parenthetical: "[T]he determination of whether a removed state court proceeding is sufficiently related to a debtor's bankruptcy to confer subject matter jurisdiction is complicated by what appears to be contradictory opinions."
citation_b.sentence: See Cambridge Place, 2010 WL 6580503, 2010 U.S. Dist. LEXIS 142954 (noting that “[t]he First Circuit has not yet addressed the appropriate standard to be applied in evaluating whether contractual indemnification obligations give rise to ‘related to’ bankruptcy jurisdiction.”); see also In re Santa Clara County Care Consortium, 223 B.R. 40 (1st Cir. BAP 1998) (“[T]he determination of whether a removed state court proceeding is sufficiently related to a debtor’s bankruptcy to confer subject matter jurisdiction is complicated by what appears to be contradictory opinions.”).