Business Reorganization

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.

Discharge Cuts Off Future Liability on a Guaranty, Some Courts Hold on a Split

The ‘conduct’ test in the Seventh Circuit, not the ‘accrual test,’ determines when a claim arose and whether it was discharged.
1st Circuit Aug 13, 2021

First Circuit Dismisses as Moot Even Though the Appeal Dealt with Payment of Money

Dismissal of a chapter 13 case moots an appeal regarding an allegedly erroneous order directing payment of money.

Debtors Can’t Easily Glom Uncashed Distribution Checks

Just because a creditor doesn’t cash a distribution check doesn’t mean it’s abandoned and reverts to the debtor.