First Circuit: Sundaram v. Briry, LLC

 

Disbursements by the trustee of assets of the estate  prior to the confirmation of the plan and prior to the dismissal of the bankruptcy case cannot be revisited in a subsequent Article III challenge.  Since the claim attempts to revisit the organization of the estate, the claim is now moot, and statutes and common law rules allowing challenges to erroneous disbursements require that the funds be in the possession of the trustee at the time that the bankruptcy case is dismissed.

http://media.ca1.uscourts.gov/pdf.opinions/20-9008P-01A.pdf