Recent First Circuit Developments and Persisting Problems Regarding Avoidance of Impairing Liens
In East Cambridge Savings Bank v. Silveira (In re Silveira), 141 F.3d 34 (1st Cir. 1998), the First Circuit Court of Appeals decided that 11 U.S.C. §522(f) 1 permits only partial avoidance of judicial liens in situations where a debtor has equity in excess of his or her