Sanders Confectionery Products Inc. v. Heller Financial, Inc.

How later courts describe this case

• holding that dismissal for failure to appear at a deposition is on the merits
• holding that core bankruptcy proceedings can preclude non-core proceedings
• holding direct and indirect subsidiaries are in privity with corporate parent
• affirming dismissal of debtor’s lender liability action as res judicata of the prior bankruptcy proceeding
• "A core proceeding either invokes a substantive right created by federal bankruptcy law or one which could not exist outside of bankruptcy.”
• for res judica-ta, “whether the second suit involves the same cause of action ... depends ... upon the scope of the compulsory counterclaim rule.”
• "A core proceeding either invokes a substantive right created by federal bankruptcy law or one which could not exist outside of the bankruptcy."
• Core proceedings concern rights “created by federal bankruptcy law or ... which could not exist outside of the bankruptcy.”