2nd Circuit

2nd Circuit May 8, 2019

Disclosing an Asset in the Wrong Place Won’t Invoke Judicial Estoppel, Circuit Says

Second Circuit won’t give a defendant a windfall if the debtor scheduled the lawsuit in the wrong place but told the trustee and the court.

Freezing a Chapter 7 Debtor’s Bank Account Doesn’t Violate the Automatic Stay

SDNY opinion seems to mean that a bank may freeze a debtor’s entire bank account at filing, without violating the automatic stay.
2nd Circuit Connecticut Jan 31, 2019

Connecticut Joins New York on Fraudulent Transfers for Children’s Tuition

Student’s entitlement to a refund determines whether a parent’s tuition payments are constructively fraudulent transfers.

The Emily Litella Principle Governs the Withdrawal of Proofs of Claim

Withdrawing a proof of claim will not divest the bankruptcy court of jurisdiction to try an avoidance action without a jury, Judge Bernstein says.

Tuition Payments by Insolvent Parents (Likely) Constitute Fraudulent Transfers

District judge in Brooklyn overturns the bankruptcy court and again exposes colleges and universities to the receipt of fraudulent transfers when insolvent parents pay their childrens’ tuition.

New York Judge Rails Against the Use of ‘Appearance Counsel’

Multiple ethical violations may occur with the use of so-called appearance counsel in consumer bankruptcies.
2nd Circuit Vermont Jul 20, 2018

A Convert Joins the Minority Interpretation of the Repeat-Filing Stay Termination

Bankruptcy Judge Colleen A. Brown of Burlington, Vt., changes her position on Section 362(c)(3)(A).