Uniform Commercial Code/Article 9

3rd Circuit New Jersey Nov 18, 2024

Without Levy, a Recorded Judgment Lien Is Unperfected in Some States

In New Jersey, a trustee’s hypothetical judicial lien has priority over a judgment lien if the judgment lienholder has not made a levy on the property.
2nd Circuit Connecticut Dec 20, 2024

A Mortgage Deficiency Judgment Is a Judicial Lien Subject to Avoidance Under § 522(f)

A deficiency judgment resulting from mortgage foreclosure is not ‘a judgment arising out of a mortgage foreclosure’ and can be avoided as a judgment lien.

A Consensual Judgment Is a Judgment Lien Subject to Avoidance Under Section 522(f)

‘Obtained by’ legal proceedings, a consent judgment is still a judgment lien that can be avoided if it impairs an exemption.