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See e.g., Resorts, 372 F.3d at 161 ("If there is no jurisdiction under 28 U.S.C. § 1334 or 28 U.S.C. § 157, retention of jurisdiction provisions in a plan of reorganization or trust agreement are fundamentally irrelevant."); In re Holly's Inc., 172 B.R. 545, 555-56 (Bankr. W.D. Mich. 1994), aff 'd, 178 B.R. 711 (W.D. Mich. 1995) (noting retention of jurisdiction provision in confirmed plan may correctly state court's post-confirmation jurisdiction over particular proceedings; however, court determines that subject matter jurisdiction post-confirmation not on basis of that retention of jurisdiction plan provision, but rather on basis of federal statute defining subject matter jurisdiction for bankruptcy cases and proceedings); see also In re Goodman Bros. Steel Drum Co., Inc., 247 B.R. 604, 612 (Bankr. E.D. N.Y. 2000) (noting plan provision stating that bankruptcy court would retain jurisdiction to adjudicate any pending claims was insufficient to confer jurisdiction where court would not otherwise have jurisdiction). Where a bankruptcy court has jurisdiction to hear a matter under federal statutes, however, plan jurisdictional retention provisions will be honored. Resorts, 372 F.3d at 161.
Jurisdiction "arising under title 11" or "arising in cases under title 11" typically raise fewer jurisdictional issues than does a bankruptcy court's "related to" jurisdiction. With respect to "related to" jurisdiction, it is generally held that a bankruptcy court's jurisdiction is reduced after plan confirmation. See, e.g., Resorts, 372 F.3d at 164; In re Craig Store's of Texas, Inc., 266 F.3d 388, 388 (5th Cir. 2001) ("After a debtor's reorganization plan has been confirmed, the debtor's estate, and thus bankruptcy jurisdiction, ceases to exist, other than for matters pertaining to the implementation or execution of the plan."); In re Fairfield Cmtys., Inc., 142 F.3d 1093, 1095 (8th Cir. 1998); In re Johns-Manville Corp., 7 F.3d 32, 34 (2d Cir. 1993); Goodman v. Phillip Curtis Enter., Inc., 809 F.2d 228, 232 (4th Cir. 1987); AstroPower Liquidating Trust v.
