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.’
Fourth Circuit: State Law Claims for Discharge Violations Are Not Preempted
The Fourth Circuit declined to follow the First and Sixth Circuits on preemption of automatic stay violations by expanding the ban to redress for discharge violations.