What is the "reasonable value of services" standard for a severance claim?

federal, United States of America

The following excerpt is from Meruelo v. Reorganized Meruelo Maddux Props., Inc. (In re Meruelo Maddux Props., Inc.), BAP No. CC-13-1494-KiTaD (B.A.P. 9th Cir. 2014):

NLRB v. Bildisco & Bildisco, 465 U.S. 513, 531 (1984). This "reasonable value of services" standard appears to be what the bankruptcy court applied to both the 2011 bonus claim and the severance claim. While this may be the proper standard to apply for compensation consisting of wages or something akin to wages when a contract has not yet been assumed or is non-existent, it does not apply to severance claims.

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