debtor case for creditors who were deemed unimpaired under a plan (as opposed to the federal judgement rate, which would make them impaired). And there is very recent opposing authority in Delaware that finds creditors of a solvent debtor remain unimpaired if they receive interest at the federal judgement rate. Therefore, the issue remains open in many jurisdictions and will be closely monitored going forward, especially considering the impact such disparate rates can have on creditors’ recoveries in large, solvent debtor cases.Notes: All references to a “Section” will be to those under title 11 of the U.S. Code (the “Bankruptcy Code”) unless noted otherwise. 46 F.4th 1047 (9th Cir. 2022). 11 U.S.C. §502(b)(2). 11 U.S.C. § 506(b). 11 U.S.C. § 726(b)(5).PG&E at 1051.See 28 U.S.C. § 1961(a). The post-judgment interest rate for judgments entered from September 26 through October 2, 2022 is 4.08%. https://www.casb.uscourts.gov/post-judgment-interest-rates (accessed October 5, 2022). Cal. Civ. Code § 3289(b). 11 U.S.C. § 1124(1). 285 F.3d 1231 (9th Cir. 2002).In re Ultra Petroleum Corp., 624 B.R. 178, 203–04 (Bankr. S.D. Tex. 2020).In re Energy Future Holdings Corp., 540 B.R. 109, 124 (Bankr. D. Del. 2015).In re The Hertz Corp., 637 B.R. 781, 800–01 (Bankr. D. Del. 2021). 11 U.S.C. § 1129(a)(7)(A)(ii). U.S.C. § 1129(b)(1).PG&E at 1056 (emphasis added), offering In re Dow Corning Corp., 456 F.3d 668, 680 (6th Cir. 2006) and In re Mullins, 633 B.R. 1, 20 (Bankr. D. Mass 2021) as support for such proposition. An appeal of the decision of In re Ultra Petroleum Corp., 624 B.R. 178, 203–04 (Bankr. S.D. Tex. 2020); oral argument was held on October 4, 2021 and matter remains under advisement.In re The Hertz Corp., 637 B.R. 781, 800–01 (Bankr. D. Del. 2021).[View source.]