William R. Sawyer

Judge Court Middle District of Alabama

Student Loans Were Discharged Only with Assistance from Pro Bono Counsel

A debtor with negative disposable income was forced to go through two trials and three appeals to discharge student loans.
11th Circuit Aug 30, 2021

Pawn Loans May Be Modified in Chapter 13 if There Wasn’t a Default Before Filing

Eleventh Circuit limits its own precedent to say that pawn lenders aren’t entirely immune from bankruptcy.

Bar Date Not Extended Three Days for Service by Mail

As bar dates are fixed by the meeting of creditors, not by date of mailing, Rule 9006(f) isn’t applicable.