Thus every decision could merit watching. To take one instance, the Heather Apartments ruling, says Keith Miles Aurzada of Powell Goldstein LLP, will "make confirming plans of reorganization for single-asset real estate debtors much more difficult, especially where they don't generate enough cash flow to pay interest. It really puts teeth in the provisions of the Code that require a debtor to file a plan or commence paying interest within 90 days of the petition date."

But what are the ramifications of Kishel's ruling, which Aurzada says is the first to address the requirements for an extension? Bankruptcy attorneys are split.

Aurzada, who has been involved in several SARE cases but not Heather Apartments, says, "This is going to give [lenders] a little firmer ground to make decisions. It's always been a lack of judicial decisions in the past that has made lenders uneasy."