David B. Wheeler

Jan 11, 2017

Consensual Redemption Agreements Outside the Scope of Judicial Authority

The most embattled creditor in the consumer bankruptcy arena in recent years has been Sears Roebuck and Co. 1 In the following cases, Sears again finds itself at center stage in a consumer bankruptcy controversy. This time, the controversy relates to the validity of

Jan 11, 2017

Whose Property Is It Anyway Evaluating the Rights and Obligations of Post-confirmation Debtors and Creditors in Chapter 13

For a number of years, bankruptcy courts have been wrestling with the issue of the status of a debtor's chapter 13 estate once a plan of reorganization has been confirmed. Not surprisingly, the resolution of this issue works a significant impact upon the rights of a

Practice and Procedure Jan 11, 2017

Lien Revival Under Section 349: In re Booth

Consumer creditors were dealt a favorable hand on the issue of lien "revival" or "revesting" in a recent decision authored by Judge Eugene R. Wedoff in In re Booth. 1 The issue presented in Booth is the effect of dismissal of a chapter 13 case in which the secured

Jan 11, 2017

Section 108 Toll or Trap

One of the most frequently asked questions by persons ensnared in a bankruptcy for the first time is the bankruptcy's effect on a creditor's right to pursue a claim against the debtor. Often overlooked by debtors and creditors alike, 11 U.S.C. §108 1 prescribes the

Jan 11, 2017

In re Jamo 1st Circuit Increases Creditor Leverage in Reaffirmations

The consumer creditor community recently received a gift from an unlikely source—the First Circuit Court of Appeals. In the case of Jamo v. Katahdin Federal Credit Union (In re Jamo), 1 the appeals court set aside the holding of the bankruptcy court and the First

Jan 11, 2017

Redemption Under 722 Possible End-run Around Rash

In June 1997, the Supreme Court handed down Associates Commercial Corporation v. Rash. 1 Certiorari having been granted to resolve the conflict among the circuits on the issue of valuation in a chapter 13 cramdown, it was hoped that the court would enunciate a bright