United Savings Assoc. of Texas v. Timbers of Inwood Forest Assoc.

United Savings (plaintiff) was undersecured on its loan to Timbers (debtor), whose appreciating apartment project was worth less than the outstanding debt, when Timbers filed Chapter 11 and triggered the automatic stay; United Savings sought relief from the stay for lack of adequate protection under Section 362(d)(1), and the bankruptcy court instead conditioned continuing the stay on Timbers making ongoing market-rate interest payments, a ruling the Fifth Circuit ultimately reversed.