Consumer Bankruptcy

4th Circuit May 24, 2019

Fourth Circuit Eliminates a Split on Modifying Short Term Mortgages in Chapter 13

Joining two other circuits, the Fourth Circuit now permits a chapter 13 debtor to strip down a short term home mortgage to the value of the property.
6th Circuit May 21, 2019

Sixth Circuit Muses on Whether ‘Prudential Standing’ Applies in Bankruptcy

New judge on the Sixth Circuit raises a host of questions about the requisites of standing in bankruptcy court.

‘Earmarking’ Only Applies When a Debtor Receives a Loan from a Third Party

Money taken from a debtor’s own retirement account to pay a creditor does not qualify for the earmarking defense, Chief Judge Fehling says.

Did Segal Survive Butner in Defining Property of the Estate?

Judge Perkins in Illinois says the ‘sufficiently rooted’ test from Segal v. Rochelle did not survive Butner and the adoption of the Bankruptcy Code.
9th Circuit May 6, 2019

Direct Mortgage Payments Are ‘Under the Plan,’ Ninth Circuit BAP Says

BAP joins the majority of courts by saying that defaulting on direct mortgage payments precludes a chapter 13 debtor from receiving a discharge.