Three Circuits Now Say ‘13’ Trustees Aren’t Paid if Dismissal Precedes Confirmation
The same question has been sub judice in the Second Circuit for 15 months. Is the Second Circuit on the cusp of making a circuit split?
Eleventh Circuit Reads Husky Narrowly, Perhaps Too Narrowly
Reading Husky narrowly, the Eleventh Circuit requires that fraud occur before a debt arises to make the debt nondischargeable under Section 523(a)(2)(A).