Claims

3rd Circuit Delaware Aug 18, 2021

Issue and Claim Preclusion Didn’t Bar Challenging a Lien Previously Considered Valid

Newly applicable law permitted a chapter 13 debtor to cram down a lien that the debtor previously had considered to be valid.
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.

Who Gets Insurance Proceeds When a Car Is ‘Totaled’ in Chapter 13?

Judge Callaway explains when a debtor keeps insurance proceeds and when it goes to creditors under a chapter 13 plan.
6th Circuit Aug 16, 2021

Sixth Circuit Erects Barriers to FDCPA Suits by Consumers in a 2/1 Opinion

A statutory violation by itself won’t necessarily give a plaintiff constitutional standing.

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.

In ‘Chapter 20,’ Discharged Mortgage Claim Resurrects as Unsecured, EDNY Judge Says

Judge Grossman didn’t abolish ‘chapter 20’ entirely. He required the debtor to treat the subordinate mortgage lender like all other unsecured creditors, even though the debtor’s personal liability to the lender had been discharged in the prior chapter 7 case.