Bankruptcy Litigation

9th Circuit May 16, 2022

Nonjudicial Foreclosure Wipes Out Deficiencies for the FCRA, Ninth Circuit Says

The Ninth Circuit equates nonjudicial foreclosure with bankruptcy discharge in terms of the effect on deficiencies following foreclosure.
1st Circuit May 6, 2022

Circuits More Deeply Split on Waiver of Sovereign Immunity for Native American Tribes

Over a vigorous dissent, the First Circuit Joins the Ninth Circuit by holding that Section 106(a) waives tribes’ sovereign immunity.
9th Circuit Mar 25, 2022

Debtor Can’t Be Punished for Shifting Legal Theories After an Unfavorable Decision

ate law might provide an equitable basis for denying a state-law exemption, although Law v. Siegel won’t permit equity to defeat an exemption claim under federal law.

The Two-Year Complaint Deadline Can’t Be Extended Without Notice to Defendants

Equitable tolling can extend the two-year deadline for filing complaints, but the deadline can’t be extended without notice to the defendants, even if they are unknown or unknowable.
6th Circuit Dec 27, 2021

Split Grows on Barring Fraudulent Transfer Attacks on Real Estate Tax Foreclosures

Circuit courts differ on their understanding of Supreme Court precedent and are now split 3/3 on whether a real estate tax foreclosure can be set aside as a constructive fraudulent transfer.