9th Circuit Hawaii Dec 17, 2024

Debt Held Nondischargeable as to Someone Who Didn’t Commit a Defalcation

Quick Take Bartenwerfer held to make a debt nondischargeable as to someone who was neither a partner nor an agent.
2nd Circuit Connecticut Dec 20, 2024

A Mortgage Deficiency Judgment Is a Judicial Lien Subject to Avoidance Under § 522(f)

Quick Take A deficiency judgment resulting from mortgage foreclosure is not ‘a judgment arising out of a mortgage foreclosure’ and can be avoided as a judgment lien.