Consumer Bankruptcy

11th Circuit Jul 14, 2021

General Default Judgment Didn’t Satisfy Requirements of Issue Preclusion, Circuit Says

If the complaint was properly plead, a general default judgment might invoke issue preclusion to bar discharge of a debt.
1st Circuit Puerto Rico Jun 29, 2021

Puerto Rico Case and the Efficacy of Prof. Westbrook’s Definition of ‘Executoriness’

The bankruptcy community needs a better definition of what’s an executory contract, and Prof. Jay Westbrook has it.
2nd Circuit Jul 15, 2021

All Private Student Loans Are Not Excepted from Discharge, Second Circuit Holds

No circuit split: The Second Circuit agrees with the Fifth and Tenth Circuits that only a subset of private student loans is automatically nondischargeable.
8th Circuit Minnesota Jul 7, 2021

Tribal Law Defined the Nature of a Tribe Member’s Property Interest in Gaming Revenue

Federal law allows tribes to determine whether a tribe member’s interest in distributions of gaming revenue will be estate property in bankruptcy, Judge Ridgway says.

Fees Benefiting Only the Debtor — and Not the Estate — Are Compensable in Chapter 13

Section 330(a)(4)(B) is an exception to the American Rule and the notion that administrative expenses must benefit the estate, not just the debtor.
3rd Circuit New Jersey Jun 24, 2021

Amended Chapter 13 Plan Allowed to Cure Post-Petition Mortgage Defaults

Courts are split on whether a debtor may amend a chapter 13 plan to cure post-petition defaults on a principal residence.