Joseph G. Rosania, Jr.

Judge Court District of Colorado
10th Circuit Colorado May 24, 2024

Avoidance of ‘Impairment’ Liens Can’t Be Delayed until Discharge in Chapter 13

If a ‘13’ case is dismissed after confirmation, the holder of an avoided lien retains remedies under state law, Judge Rosania says.
10th Circuit Colorado May 12, 2020

An Exempt Asset Effectively Loses Its Exemption in Chapter 13

Lower courts are split on whether an exempt asset is included in the calculation of “projected disposable income” in chapter 13.