I think Levine fails to note one benefit of invalidating non-debtor releases.<p>Yes, the current victims suffer from having less money available to a settlement.<p>But future victims may be better protected, as non-debtors now can't exploit a bankruptcy case to settle their liability. They are more vulnerable to expensive litigation, and draining of their assets unless they shield them offshore and probably stay out of the country. This could be a potential deterrent to future malfeasance.