On February 20, Zi C. Lin, Edet Nsemo, and Motunrayo D. (M.D.) Akinmurele obtained a bankruptcy in rem bar order in the United States Bankruptcy Court for the District of Nevada for client Kwala, LLC in In re Pacific Panorama. The published memorandum decision on Kwala’s request for in rem relief from the automatic stay, available here, states that the client, whose foreclosure sale was delayed multiple times by bad faith bankruptcy filings, is “clearly entitled to the relief it has requested” under 11 U.S.C. section 362(d)(4). The opinion holds that bankruptcy courts can no longer use their inherent powers under 11 U.S.C. section 105(a) to grant relief from the automatic stay due to the U.S. Supreme Court’s holding in Law v. Siegel, 571 U.S. 415 (2014), and examines the different avenues for obtaining in rem bar relief from the automatic stay absent section 105(a).