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New Mexico Feb 9, 2026

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.

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