June 22, 2017 Split Sixth Circuit Bars Litigation Trustees from Suing on D&O Policies Dissent proclaims a split of circuits and says the debtor and DIP are distinct entities. 6th Circuit , December 15, 2015 Sixth Circuit Splits with Third on Substantial Contribution in Chapter 7 Creditors, rejoice! Substantial contribution is rewarded, at least in the Sixth Circuit. 6th Circuit ,