Consumer Bankruptcy

New EOUST Director Discusses the Path to Her Position, Tackling Current Challenges and What Lies Ahead

New EOUST Director Discusses the Path to Her Position, Tackling Current Challenges and What Lies Ahead T ara Twomey was appointed director of the Executive Office for U.S. Trustees (EOUST) on Feb. 27, 2023. She was previously executive director of the National Consumer

9th Circuit Nov 21, 2023

Ninth Circuit: State Law Can’t Require More than What Rule 3001 Requires for Claim Validity

Reversing the BAP, the Ninth Circuit (erroneously) holds that state law cannot demand more documentation for a proof of claim than Bankruptcy Rule 3001 requires for prima facie validity.

Discharge Isn’t an Automatic Bar to Conversion from ‘7’ to ‘13’

A district court opinion from Michigan raises the question of whether the Supreme Court’s decision in Marrama is still good law after Law v. Siegel.

Benchnotes January 2024

Benchnotes By Bradley D. Pack, Aaron M. Kaufman and Christina Sanfelippo BAPCPA Did Not Abrogate Absolute-Priority Rule in Chapter 11 Cases Hon. Peter D. Russin of the U.S. Bankruptcy Court for the Southern District of Florida recently ruled that the absolute-priority

9th Circuit Nov 13, 2023

‘13’ Debtors May Bifurcate Mortgages that Mature Before the Final Plan Payment

The Ninth Circuit BAP says that a later valuation can make a debtor eligible for chapter 13 when the original schedules meant ineligibility.

Even Without Personal Liability, a Mortgage on a Debtor’s Property Is a ‘Claim’

The ‘broad’ definition of ‘claim’ by the Supreme Court in Johnson led Judge Huennekens to hold that in rem rights against a debtor’s property give rise to a ‘claim.’