If Personal Liability on a Mortgage Was Discharged, Is Confirmation Possible in ‘13’?
When there was a prior discharge of personal liability on a mortgage note, what’s the theory for confirming a plan in a subsequent chapter 13 case?
A ‘13’ Plan Can’t Pay Nondischargeable Debt in Full and Give Nothing to Other Creditors
Bankruptcy Judge Jeffery Deller of Pittsburgh defines impermissible discrimination among unsecured creditors in a chapter 13 plan.
A Deceased Debtor’s Survivor Can Make Chapter 13 Plan Payments from Her Income
Even though a deceased chapter 13 debtor has no regular income, the plan can still be confirmed.
Benchnotes August 2025
Benchnotes By Aaron M. Kaufman, Bradley D. Pack and Christina Sanfelippo 1 Ninth Circuit: Section 1322(c)(2) Allows Bifurcation of Short-Term Loans Secured Against Debtors’ Primary Residences In Mission Hen LLC v. Lee, 2 the Ninth Circuit considered whether the debtor’s