ATP (disclosure: represented them once forever ago in an unrelated matter) filed for bankruptcy. Before it did, it sold "term overriding royalty interests" in its oil and gas leaseholds to OHA Investment. But even before that, ATP hired service providers to, well, provide services. Under the Louisiana Oil Well Lien Act, those service providers had secured interests against ATP's leaseholds.
ATP files for bankruptcy. The service providers want to collect on their secured debts, only to find out those are - maybe - owed by OHA, not ATP, because they've been transferred. So this amounts to the service providers going after OHA under the LOWLA.
OHA argues it doesn't actually have an interest in the oil and gas; it only has an interest in the proceeds from their sale. Therefore, OHA further agues, the service providers don't actually have a secured interest - the security goes to the holdings, not the stream of profits from the holdings. Nuh-uh, says the Court - that's slicing the bologna a little too thin.
So OHA is in bad shape. But the LOWLA has a safe-harbor: a bona fide purchaser without notice of the security interest is A-OK. OHA never had notice of the service providers' interests, or at least not before purchase. Result? OHA wins.
Author of the opinion? Judge Reavley, who is now ninety-six years old.