Wallis v. Justice Oaks II, Ltd.

How later courts describe this case

• acknowledging Florida’s adoption of the “transactional” test set forth in Restatement (2d) of Judgments § 24 (1982)
• creditor lost its right to object to another creditors claim once the bankruptcy court confirmed the debtor’s plan
• order confirming a plan of reorganization is entitled to preclusive effect on all claims or issues which were raised or could have been raised in the confirmation proceedings
• an objection that challenges the classification of a claim must be made before confirmation of the chapter 13 plan or it will be deemed allowed by the confirmation order
• although addressing the issue as one of finality, circuit court refused to apply res judicata where bankruptcy court, in entering order approving settlement, “consider[ed] many factors other than the merits” of the underlying dispute
• bankruptcy court’s order confirming a reorganization plan entitled to res judicata effect