Utah Oct 27, 2025

Courts Split on Modifying a ‘13’ Plan to Surrender a Car with the Deficiency Unsecured

Quick Take Bankruptcy Judge Hunt in Salt Lake City split with the Sixth Circuit, which held that a debtor can’t modify a plan by surrendering a car but must continue paying the auto lender in full.

Despite Schwab, Unlimited Exemptions Require an Objection Before the Deadline

Quick Take Judge Isicoff explains why Schwab refines but does not overrule Taylor and why Schwab does not apply to unlimited exemptions.