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1st Circuit Maine Mar 14, 2025

Middle Ground on the Circuit Split over Dismissal vs. Conversion in Chapter 13

Bankruptcy Judge Michael Fagone permits dismissal of a chapter 13 case, but with a bar to refiling within two years.
9th Circuit Apr 8, 2025

On a Split, Ninth Circuit BAP Holds: Misconduct in ‘11’ Doesn’t Prevent Conversion to ‘7’

Given that chapter 7 has remedies like denial of discharge for a debtor’s misconduct, bad faith in chapter 11 doesn’t allow dismissal on conversion to chapter 7.

Giving Debtors Their Fair Shake: What Happens to Nonexempt Equity Increases in Debtors’ Homes in Converted Chapter 7 Cases

Giving Debtors Their Fair Shake: What Happens to Nonexempt Equity Increases in Debtors’ Homes in Converted Chapter 7 Cases By Andrew Bates 1 Following decisions from the Eighth and Ninth Circuits, chapter 13 filers could find themselves in a difficult predicament