After the Supreme Court affirmed a Ninth Circuit ruling in Executive Benefits Ins. Agency v. Arkison on June 9 that permits bankruptcy judges to make recommendations in certain matters that may later be adopted by a federal court, but side-stepped the issue of whether Article III of the Constitution permits a bankruptcy court to make final rulings in that matter if the parties consent, Dennis J. Nolan, Chair of Anderson Kill's Bankruptcy and Restructuring Group, commented as follows in Law360: