Note:
Stephen L. Poe, The Automatic Stay of the 1978 Bankruptcy Code Versus the Norris-LaGuardia Act: A Bankruptcy Court’s Dilemma, 61 TEXAS L. REV. 321 (1982).
 

Abstract:
In this Note, Poe addresses the question of whether the bankruptcy code’s automatic stay provision applies to a creditor-labor union. Under the pre-1978 bankruptcy code, courts had held that there was an exception in the bankruptcy code’s automatic stay provision for such creditor-labor unions. However, the 1978 code only addressed an automatic stay exception for those organizations engaged in labor disputes. This Note criticizes the Second Circuit’s preservation of the pre-1978 blanket exception and argues for a more limited exception that better interprets the 1978 code.