In a recent bankruptcy decision, In Re Tribune Co., the Third Circuit held that debt subordination agreements need not be “strictly enforced” when confirming a non-consensual chapter 11 plan. In this article, we discuss the Tribune case, the relevant debt tranches, the plan and the dispute, as well as the lower court decisions and the Third Circuit ruling. Lastly, the article closes with four reasons why the Tribune decision does not represent a “seismic shift” on the enforceability of subordination agreements in bankruptcy.