Mootness of Interlocutory Appeals After Bankruptcy Stay Relief:
Commentary on In re 155 Chambersfood, Inc. (2d Cir. Nov. 26, 2025)

I. Introduction

This commentary analyzes the Second Circuit’s summary order in In re 155 Chambersfood, Inc., No. 25‑472‑bk (2d Cir. Nov. 26, 2025), affirming the Eastern District of New York’s dismissal of a bankruptcy appeal as moot.

The dispute arose from a commercial landlord–tenant conflict in which a small pizzeria, 155 Chambersfood, Inc. (“155 Chambers” or the “Debtor”), sought Chapter 11 protection on the eve of eviction. The automatic stay under 11 U.S.C. § 362(a) halted the landlord’s eviction efforts, prompting the landlord–creditor, Manhattan Realty Co. 1, LP (“Manhattan Realty”), to move for relief from the stay under § 362(d) and, when the bankruptcy court did not promptly rule, to pursue an interlocutory appeal.

By the time the District Court addressed the appeal, the bankruptcy court had already lifted the stay and the Chapter 11 case itself was later dismissed. The District Court (Merchant, J.) dismissed Manhattan Realty’s interlocutory appeal as moot, and the landlord appealed that dismissal to the Second Circuit.

The Second Circuit’s nonprecedential summary order does not create binding circuit precedent, but it offers a clear, structured application of Article III mootness in the bankruptcy context, particularly:

• When relief from the automatic stay has already been granted; and
• Where a party attempts to avoid mootness by invoking the “capable of repetition, yet evading review” and “collateral consequences” doctrines, including a claimed interest in attorney’s fees.

The opinion is particularly instructive for creditors who seek to challenge delays in bankruptcy courts’ handling of stay-relief motions under § 362(e), and for litigants who hope to preserve fee claims by keeping otherwise-resolved disputes alive.

II. Factual and Procedural Background

A. The Parties and Underlying Dispute

Manhattan Realty Co. 1, LP is a commercial landlord that owns multiple mixed-use properties. One of its tenants was 155 Chambersfood, Inc., which operated a small pizzeria in lower Manhattan. In 2023, 155 Chambers fell behind on rent, and Manhattan Realty pursued eviction in state court.

Five days before the scheduled eviction, 155 Chambers filed a voluntary Chapter 11 petition in the U.S. Bankruptcy Court for the Eastern District of New York. This filing triggered the automatic stay under 11 U.S.C. § 362(a), which halted the eviction proceedings.

B. Motion for Relief from the Automatic Stay and § 362(e)

Manhattan Realty moved in the bankruptcy court under 11 U.S.C. § 362(d) to lift the automatic stay so that it could proceed with eviction. Section 362(e) imposes tight timing requirements on such motions:

• A preliminary hearing must be held within 30 days of the motion; and
• A final hearing must be concluded within 30 days after the preliminary hearing, unless the parties consent to an extension or the court finds “compelling circumstances” justifying more time.

If the court does not comply with those timing rules (and does not validly extend the period), § 362(e)(1) provides that the stay “is terminated” by operation of law with respect to the requesting party.

The bankruptcy court held hearings on Manhattan Realty’s motion on September 26, 2023, October 24, 2023, and December 5, 2023, but declined to adjudicate the motion at those hearings.

C. Interlocutory Appeal to the District Court

On December 18, 2023, frustrated with the lack of a decision, Manhattan Realty filed an interlocutory appeal in the Eastern District of New York. It argued that:

• The bankruptcy court had failed to comply with the timing requirements of § 362(e); and
• As a consequence, the automatic stay had already terminated by operation of law under § 362(e)(1).

The practical relief Manhattan Realty sought was clear: a ruling that the bankruptcy stay was (or should be deemed) lifted so that the landlord could complete the eviction.

D. Subsequent Bankruptcy Court Actions and Dismissal of the Case

While Manhattan Realty’s appeal was pending in the District Court:

• On April 8, 2024, the bankruptcy court lifted the automatic stay, expressly permitting Manhattan Realty to proceed with eviction.
• On August 6, 2024, 155 Chambers moved to voluntarily dismiss its Chapter 11 case, and on September 27, 2024, the bankruptcy court granted that motion, dismissing the Chapter 11 case.

On February 3, 2025, the District Court entered judgment dismissing Manhattan Realty’s interlocutory appeal as moot. Manhattan Realty then appealed that dismissal to the Second Circuit.

III. Summary of the Second Circuit’s Decision

The Second Circuit affirmed the District Court’s dismissal of the appeal as moot. The panel (Walker, Carney, and Nardini, JJ.) reviewed the mootness question de novo, citing Fund for Animals v. Babbitt, 89 F.3d 128, 132 (2d Cir. 1996).

A. Core Holding on Mootness

The court concluded that Manhattan Realty’s appeal became moot when the bankruptcy court lifted the automatic stay on April 8, 2024. At that point:

• Manhattan Realty had obtained all the relief it had sought with respect to the stay—namely, termination of the stay so eviction could proceed; and
• There was no further effective relief the District Court (or the Second Circuit) could grant regarding that motion.

As the court put it, echoing Ruesch v. Commissioner of Internal Revenue, 25 F.4th 67, 70 (2d Cir. 2022), “no live controversy remains where a party has obtained all the relief [it] could receive on the claim through further litigation.”

B. Rejection of the “Capable of Repetition, Yet Evading Review” Exception

Manhattan Realty argued that its challenge to the bankruptcy court’s failure to timely decide the stay-relief motion was “capable of repetition, yet evading review.” The Second Circuit rejected this argument, holding:

• There was no reasonable expectation that Manhattan Realty and 155 Chambers would again be in a similar bankruptcy dispute, especially since the Chapter 11 case was dismissed.
• Even assuming the same adversary was not required, Manhattan Realty’s assertion that, as a landlord with 24 mixed-use properties, it might again be subject to stay-related delay was too speculative and theoretical to satisfy the exception.
• Bankruptcy decisions on automatic stays do not inherently evade review; litigants can seek expedited appeals or extraordinary writs such as mandamus.

C. Rejection of a “Collateral Consequences” Theory Based on Attorney’s Fees

Manhattan Realty also contended that the appeal remained live because it supposedly had a continuing injury: the lack of a procedural mechanism to pursue attorney’s fees for the bankruptcy court’s alleged mishandling of the stay-relief motion. It attempted to frame this as a “collateral consequence” akin to those recognized in criminal cases.

The Second Circuit held that:

• The continuing “collateral consequences” presumption, recognized in criminal cases like Sibron v. New York, 392 U.S. 40 (1968), and discussed in Nowakowski v. New York, 835 F.3d 210 (2d Cir. 2016), does not apply in this civil, bankruptcy-related context.
• More broadly, under Steel Co. v. Citizens for a Better Environment, 523 U.S. 83, 107 (1998), an interest in attorney’s fees alone cannot create an Article III case or controversy when none exists on the merits.

Because Manhattan Realty’s appeal to the District Court concerned only the bankruptcy court’s failure to decide a motion to lift the stay—and that issue had since been fully overtaken by events—the landlord’s desire to leverage a ruling to support a fee claim could not keep the case alive.

Accordingly, the Second Circuit affirmed the District Court’s judgment dismissing the appeal as moot.

IV. Precedents and Authorities Cited

A. Article III Mootness and Justiciability

• Already, LLC v. Nike, Inc., 568 U.S. 85 (2013)
  Cited for the foundational rule that a case must involve an “actual controversy” under Article III that exists “through all stages of the litigation.” A case becomes moot when issues are no longer “live” or the parties lack a legally cognizable interest in the outcome. This frames the entire analysis.

• Ruesch v. Comm’r of Internal Revenue, 25 F.4th 67 (2d Cir. 2022)
  Quoted for the proposition that “no live controversy remains where a party has obtained all the relief [it] could receive on the claim through further litigation.” The Second Circuit applies this principle to conclude that, once the stay was lifted, Manhattan Realty received all it had sought in the appeal.

• Fund for Animals v. Babbitt, 89 F.3d 128 (2d Cir. 1996)
  Cited for the standard of review: questions of mootness and standing are reviewed de novo, as they are questions of law.

B. “Capable of Repetition, Yet Evading Review” Exception

• Exxon Mobil Corp. v. Healey, 28 F.4th 383 (2d Cir. 2022)
  Provides the two-part test for the “capable of repetition, yet evading review” exception:

  • The plaintiff must have a reasonable expectation of being subjected to the same challenged action again; and
  • The challenged conduct must be of such short duration that it is too short to be fully litigated before ceasing.

• Dennin v. Conn. Interscholastic Athletic Conf., Inc., 94 F.3d 96 (2d Cir. 1996)
  Cited for the Second Circuit’s view that the exception generally applies where the same parties are reasonably likely to find themselves again in dispute over the same issues. The court uses this to emphasize that, after dismissal of 155 Chambers’ bankruptcy, it is not reasonably likely that these same parties will be in an analogous dispute.

• Van Wie v. Pataki, 267 F.3d 109 (2d Cir. 2001)
  Quoted for the point that a supposed future injury cannot be merely “speculative and theoretical.” The Second Circuit uses this phrase to reject Manhattan Realty’s argument that, as a landlord with 24 properties, it will reasonably likely face similar § 362(e) delays in the future.

C. Bankruptcy-Specific Procedural Remedies

• Satter v. KDT Indus., Inc., 28 B.R. 374 (S.D.N.Y. 1982)
  Cited as an example of a case where a litigant sought a writ of mandamus to compel a bankruptcy judge to comply with statutory timing requirements under § 362. The court mentions this to demonstrate that bankruptcy rulings on stay relief do not inevitably evade review: parties can seek expedited relief or extraordinary writs rather than rely on mootness exceptions.

D. Collateral Consequences and Attorney’s Fees

• Nowakowski v. New York, 835 F.3d 210 (2d Cir. 2016)
  Discusses the “continuing collateral consequences” presumption from Sibron v. New York, 392 U.S. 40 (1968), and clarifies that the presumption is limited and does not automatically extend to contexts where the defendant is not challenging a criminal conviction. The Second Circuit uses this to side-step Manhattan Realty’s attempt to import criminal mootness principles into a civil, bankruptcy-related appeal.

• Steel Co. v. Citizens for a Better Env’t, 523 U.S. 83 (1998)
  Quoted for the proposition that an interest in attorney’s fees is insufficient to create an Article III case or controversy where none exists on the merits of the underlying claim. The litigation must confer some substantive benefit beyond merely reimbursing litigation costs. This is central to the court’s rejection of Manhattan Realty’s fee-based mootness argument.

E. Statutory Framework: 11 U.S.C. § 362

• 11 U.S.C. § 362(a)
  Establishes the automatic stay upon the filing of a bankruptcy petition, halting actions such as eviction, foreclosure, and collection efforts. It provides the background for why Manhattan Realty could not proceed with eviction after 155 Chambers filed Chapter 11.

• 11 U.S.C. § 362(d)–(e)
  § 362(d) governs motions for relief from the stay, while § 362(e) imposes timing requirements for hearings and addresses when the stay terminates by operation of law if those requirements are not met. Although Manhattan Realty asserted that the bankruptcy court violated these provisions, the Second Circuit did not decide that statutory issue; it resolved the appeal entirely on mootness grounds.

V. The Court’s Legal Reasoning

A. Article III Mootness Once Complete Relief Is Obtained

The starting point of the Second Circuit’s analysis is the constitutional requirement that federal courts only decide “cases” or “controversies.” Under Already v. Nike, a dispute must remain live through all stages of litigation. If intervening events eliminate any effectual relief that a court can grant, the case becomes moot and must be dismissed.

Here, Manhattan Realty’s goal in both the bankruptcy court and the interlocutory appeal was to obtain relief from the automatic stay to proceed with eviction. Once the bankruptcy court lifted the stay on April 8, 2024:

• The specific controversy—whether Manhattan Realty was entitled to relief from the stay—ceased to exist; and
• No additional court order was necessary to accomplish the landlord’s practical objective.

The panel emphasizes that this was “all the relief that Manhattan Realty sought” in its motion and resulting appeal. Because it obtained that relief, the appeal no longer presented an “actual controversy” under Article III.

Importantly, the court does not reach the merits of Manhattan Realty’s statutory argument under § 362(e)(1) (that the stay had terminated earlier by operation of law). From an appellate perspective, the requested relief—termination of the stay—was already in place. Any ruling on whether the stay should be deemed to have ended earlier would be purely retrospective and of no practical consequence to the stay itself. That sets up the key question: can such retrospective interests (e.g., framing the issue for attorney’s fees) keep a case alive? The panel’s answer is no.

B. Rejection of the “Capable of Repetition, Yet Evading Review” Exception

Manhattan Realty argued that its challenge falls under a well-known exception to mootness: some disputes are so short-lived that they are almost always moot by the time appellate review occurs, yet are likely to arise again. These are “capable of repetition, yet evading review.” The court applies the Exxon Mobil two-part test:

1. There must be a reasonable expectation that the same complaining party will be subject to the same action again; and
2. The challenged conduct must be of inherently short duration so as to evade full litigation before cessation.

The Second Circuit focuses on the first prong.

1. Same Parties and Reasonable Expectation

Relying on Dennin, the court notes that the exception generally applies only where the same parties are reasonably likely to be embroiled in the same dispute again. Here:

• 155 Chambers’ Chapter 11 case was dismissed on September 27, 2024; and
• There was no indication of any ongoing relationship that would produce another bankruptcy dispute between Manhattan Realty and 155 Chambers.

Thus, the possibility of repetition between these parties is effectively foreclosed.

2. Different Parties? Still Too Speculative

The panel then assumes, “arguendo,” that the exception could apply even without the same opposing party. Even under that more generous view, Manhattan Realty’s situation fails.

Manhattan Realty argued that as a landlord with 24 mixed-use properties, it might again face a tenant’s bankruptcy filing and experience similar delays on a motion for relief from a stay. The court rejects this as too speculative and theoretical, invoking Van Wie:

• It is speculative whether future tenants will file for bankruptcy.
• It is speculative whether any such case will involve an automatic stay under § 362.
• It is even more speculative whether a bankruptcy judge, in some future case, will decline to adjudicate a stay-relief motion in a manner allegedly inconsistent with § 362(e).

This layered series of contingencies falls well below the “reasonable expectation” required to invoke the exception.

3. “Evading Review” and Available Remedies

Manhattan Realty further suggested that, absent application of this exception, bankruptcy courts’ violations of § 362(e)’s timeliness rules would evade review. The court rejects that policy-based concern, stressing that:

• Litigants can seek to expedite appeals of stay-related orders; and
• In extraordinary cases, they can petition for a writ of mandamus, as in Satter v. KDT Indus., Inc.

Thus, the problem is not inherently unreviewable; parties have procedural tools at their disposal to secure timely appellate review when necessary. This undermines the argument that delays in § 362(e) proceedings are the kind of short-lived actions that always end too quickly to be litigated fully.

C. Attorney’s Fees and the “Collateral Consequences” Doctrine

Manhattan Realty’s second main argument was that the appeal remained live because it had suffered, and was still suffering, harm from lacking a procedural path to pursue attorney’s fees for the alleged improper delay in ruling on its stay-relief motion.

The panel’s response is twofold:

1. Misplaced Reliance on “Collateral Consequences”

The “collateral consequences” doctrine, as developed in criminal law, recognizes that a criminal conviction can carry continuing legal disabilities—even after a sentence is fully served. In such cases, appeals from convictions are not moot simply because the direct punishment has ended; the conviction’s ongoing effects (e.g., on voting, firearms rights, immigration status) constitute a live controversy.

However:

• Nowakowski and Sibron concern criminal convictions, not civil disputes;
• The presumption of continuing collateral consequences does not apply when the defendant is not challenging a conviction; and
• The Second Circuit makes clear that this presumption is limited and does not translate wholesale into civil bankruptcy appeals.

Accordingly, Manhattan Realty cannot import that doctrine into this context simply by claiming ongoing economic harm related to legal fees.

2. Attorney’s Fees Cannot Sustain Jurisdiction

The more fundamental barrier arises from Steel Co.: even in civil cases, an interest in attorney’s fees alone cannot sustain federal jurisdiction.

The Second Circuit notes that:

• Manhattan Realty’s appeal to the District Court was not from any ruling on attorney’s fees; it was from the bankruptcy court’s failure to decide a motion to terminate the stay.
• Neither the bankruptcy court’s initial inaction, nor the District Court’s later mootness dismissal, had any direct bearing on whether Manhattan Realty could, in some other procedural posture, request fees.
• To keep a case alive solely “in the hopes of giving rise to a right to request attorney’s fees” is precisely what Steel Co. forbids.

The court distills this into a key statement: “The litigation must give [the party] some other benefit besides reimbursement of costs that are a byproduct of the litigation itself.” Once the substantive controversy ended (relief from the stay having been granted), any stand-alone interest in fee recovery cannot resurrect federal jurisdiction.

VI. Complex Concepts Simplified

A. Automatic Stay in Bankruptcy (11 U.S.C. § 362(a))

When a debtor files for bankruptcy, § 362(a) immediately imposes an automatic stay. This is a powerful injunction that stops:

• Evictions;
• Foreclosures;
• Collection lawsuits; and
• Most other efforts by creditors to enforce claims outside the bankruptcy court.

Policy-wise, the stay:

• Gives the debtor “breathing room” to reorganize; and
• Prevents a “race to the courthouse” in which aggressive creditors might seize assets to the detriment of others.

B. Relief from the Stay and § 362(e) Timelines

Creditors can move for relief from the stay under § 362(d). For example, a landlord may seek permission to continue an eviction, or a bank may ask to foreclose on collateral. Section 362(e) establishes timing rules to prevent the stay from becoming a de facto permanent injunction without timely judicial review:

• A preliminary hearing must occur within 30 days of the motion (preliminary hearing deadline).
• If the court decides to continue the stay after the preliminary hearing, a final hearing must be concluded within 30 days thereafter, unless:
• The parties consent to an extension; or
• The court finds “compelling circumstances” justify more time.
• If the court does not act within these timeframes (and does not properly extend them), the stay automatically terminates by statute with respect to the creditor.

Manhattan Realty’s core complaint was that the bankruptcy court did not adhere to these timelines and did not issue an order within the prescribed periods, so the stay should have been deemed terminated earlier than April 8, 2024. The Second Circuit declined to decide that statutory issue, because the case was moot regardless.

C. Interlocutory Appeals

An interlocutory appeal is an appeal from a ruling that is not final—i.e., from a decision that does not fully resolve all issues in the case. They are disfavored in federal practice because appellate courts generally wait for a complete, final judgment.

Here, Manhattan Realty appealed before the bankruptcy court made a final ruling on its stay-relief motion, arguing that the court’s failure to act itself violated § 362(e). That appeal was interlocutory. The District Court never reached the merits because, by the time it considered the matter, the bankruptcy court had already granted the relief from stay.

D. Mootness and Its Exceptions

Mootness is a constitutional limitation on federal jurisdiction. If at any point during litigation there is no longer a concrete dispute between the parties that a court can resolve with effective relief, the case must be dismissed as moot.

Two key exceptions discussed in this opinion are:

1. Capable of Repetition, Yet Evading Review
   This applies when:

   • The same party is reasonably likely to face the same problem again; and
   • The problem is short-lived by nature, so it will usually end before an appeal can be fully litigated.

   Classic examples include certain election-law disputes and pregnancy-related cases. The court held that Manhattan Realty’s situation did not satisfy this test.

2. Collateral Consequences
   Typically used in criminal cases, where a conviction can affect a person’s rights long after a sentence is served (e.g., voting, employment, immigration consequences). Even if the direct punishment is over, the appeal is not moot because the conviction still has legal effects.

   The Second Circuit clarified that this presumption does not carry over to Manhattan Realty’s civil appeal, and that an interest in attorney’s fees alone cannot sustain a case.

E. Writ of Mandamus

A writ of mandamus is an extraordinary remedy that can be used to compel a lower court or official to perform a duty required by law. It is very difficult to obtain and reserved for exceptional cases when:

• The lower court has clearly abused its discretion or exceeded its authority; and
• No adequate alternative remedy (like an ordinary appeal) is available.

By citing Satter, the Second Circuit signals that creditors who believe a bankruptcy court is failing to comply with § 362(e)’s timing mandates can, in the right circumstances, seek mandamus instead of relying on post hoc appeals that risk becoming moot.

F. Attorney’s Fees as a Jurisdictional “Tail”

Parties often seek attorney’s fees as part of litigation. However, the Supreme Court in Steel Co. made clear that fees cannot be the only stake in the case:

• If the underlying merits dispute is resolved or moot, a party cannot keep the case alive solely to obtain fees.
• The federal court must be able to grant substantive relief on the merits—fees are only a collateral consequence of that relief.

Manhattan Realty’s attempt to hinge jurisdiction entirely on potential fee claims therefore fails under well-settled law.

VII. Practical and Doctrinal Impact

Although this is a summary order and expressly nonprecedential under the Second Circuit’s local rules, it nonetheless offers clear guidance to bankruptcy practitioners and litigants more broadly.

A. For Creditors and Landlords

• Frame Relief Broadly if You Want More Than the Stay Lifted.
  Manhattan Realty’s appeal became moot because the only relief it sought was lifting the stay, which it ultimately received. If a creditor believes that a bankruptcy court’s failure to comply with § 362(e)’s timing requirements caused independent harm (e.g., lost rent, damages, rights under a lease), it should:
  • Clearly articulate additional forms of relief—such as declaratory judgments relevant to damages or other rights—beyond simply terminating the stay; and
  • Ensure those additional claims remain live even if the stay is ultimately lifted.
• Act Quickly to Avoid Mootness.
  Creditors concerned about delay in stay-relief rulings should:
  • Seek expedited treatment of their motions and appeals; and
  • In extraordinary circumstances, consider mandamus if a bankruptcy judge appears to disregard statutory timing rules.
• Do Not Rely on Fee Claims to Preserve Jurisdiction.
  This decision reinforces that:
  • An interest in attorney’s fees does not keep an otherwise moot appeal alive; and
  • Fee claims, if available at all, must be pursued through the proper procedural mechanisms and cannot drive federal jurisdiction in isolation.

B. For Debtors

• Dismissal of the Bankruptcy Can Cement Mootness.
  The dismissal of 155 Chambers’ Chapter 11 case was one of the factors showing that the same parties were unlikely to be in a similar dispute again, undercutting the “capable of repetition” argument.
• Temporal Stays May Be Effectively Insulated Once Resolved.
  Once a stay is lifted and the case winds down, challenges based solely on prior delays may well be deemed moot, limiting the exposure of debtors to long-running appeals over procedural timing.

C. For Bankruptcy Courts

• Awareness of § 362(e) Requirements.
  While the panel does not decide whether the bankruptcy judge in this case violated § 362(e), the fact that a creditor pressed such an argument to the circuit level underscores that creditors do pay attention to those timing rules. Bankruptcy judges should continue to:
  • Hold timely preliminary hearings; and
  • Either conclude final hearings within statutory limits or make clear findings of “compelling circumstances” or obtain party consent for extensions.
• Delays Can Trigger Extraordinary Relief Requests.
  The opinion’s reference to mandamus signals that persistent noncompliance could provoke extraordinary appellate remedies. While this case itself ended on mootness grounds, it illustrates the risk that consistent delay may invite more aggressive appellate oversight in future cases.

D. Doctrinal Clarifications in the Second Circuit

• Strict Application of Mootness in Civil Appeals.
  The panel’s reliance on Already and Ruesch confirms a straightforward, effects-based approach: once all practical relief on the underlying claim is obtained, appellate courts are loath to issue effectively advisory opinions, even where there may be some strategic benefit (such as fee positioning) to the appellant.
• Narrow Use of “Capable of Repetition, Yet Evading Review.”
  By emphasizing the same-party requirement and rejecting speculative predictions of future disputes, the opinion fits within a broader pattern of the Second Circuit’s reluctance to expand that exception beyond classic categories (e.g., election disputes, school years, pregnancies).
• Clear Boundary on Fee-Based Standing.
  Reaffirming Steel Co., the Second Circuit leaves no doubt that parties cannot use the prospect of attorney’s fees to create or preserve Article III jurisdiction where the substantive issues are no longer live.

VIII. Conclusion

The Second Circuit’s summary order in In re 155 Chambersfood, Inc. offers a tight, coherent application of Article III mootness principles in the bankruptcy context. It holds that an interlocutory appeal challenging a bankruptcy court’s handling of a stay-relief motion becomes moot once the stay is lifted and the appellant has obtained all the relief it sought on that motion.

The decision underscores three key points:

1. Complete Relief Ends the Case. When a party receives all practical relief sought—here, termination of the stay—there is no longer a justiciable controversy, and appellate courts will not adjudicate abstract timing disputes or issue advisory opinions about when the relief should have been granted.
2. Mootness Exceptions Are Narrow. The “capable of repetition, yet evading review” exception requires more than generalized possibilities of similar future disputes; and the criminal “collateral consequences” doctrine does not readily extend to civil cases involving procedural disputes over automatic stays.
3. Attorney’s Fees Cannot Sustain Jurisdiction Alone. An interest in recovering attorney’s fees, or in creating a predicate for a future fee claim, cannot keep a moot case alive. Parties must identify a substantive, live controversy beyond costs of litigation.

While not binding precedent, this summary order provides a clear roadmap for how the Second Circuit is likely to handle similar mootness questions in bankruptcy appeals and reinforces core Article III limits that constrain federal appellate jurisdiction even when parties seek to use those appeals for broader strategic purposes, such as future fee recovery or abstract clarification of statutory deadlines.