The 2016 Norton Annual Survey of Bankruptcy Law published the attached article by Alec P. Ostrow called “Cannily Employing a Strict Construction of the Inclusion in Administrative Expenses.” The article focuses on a surprising majority decision by the Sixth Circuit court of appeals in connection with reimbursable expenses and attorneys’ fees of creditors in bankruptcy cases. The statute expressly authorizes these reimbursements for creditors making a “substantial contribution” in chapter 9 municipality cases and chapter 11 reorganization cases. As a result, most courts and practitioners had concluded that such reimbursements were unavailable in chapter 7 liquidation cases. The majority held otherwise over a strong dissent. The article discusses the majority’s rationale and its potentially significant consequences in other contexts, especially for the payment seemingly prohibited or restricted fees, and other kinds claims.