A chapter 11 plan may not impair the rights of a mortgage lender against a co-owner who is not in bankruptcy.

Violating a PACA trust does not result in ‘defalcation while acting in a fiduciary capacity’ that makes a debt nondischargeable, Bankruptcy Judge Panos says, taking sides with the Eleventh Circuit.

Massachusetts judge explores the circuit split on barring creditors’ direct claims against non-bankrupt third parties.

Caulkett did not bar chapter 13 lien stripping, Massachusetts judge holds.