May 3, 2011
Resort to substantive consolidation should not be Pavlovian, but should be used only sparingly, with a heightened degree of due process and due consideration for harm or economic prejudice that such a remedy would occasion.
In re Wheeler, 2011 WL 597025 (Bankr. D. Idaho Feb. 11, 2011)
Suggested by Barbara Bozonie, West Principal Attorney Editor