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ABI Journal

Rochellel's Daily Wire

February 12, 2020

May a Chapter 13 Plan Pay a Larger Percentage Toward Student Loans?

Since Congress has made student loans virtually nondischargeable, why can’t a chapter 13 plan discriminate in favor of paying more toward student loans?

2nd Circuit, New York, New York Northern District

February 11, 2020

Section 362(k)(1) Sanctions Apply to Automatic Stay Violation Continuing After Discharge

Almost $35,000 in actual and punitive damages was imposed on a judgment creditor and its collection law firm for failing to vacate a garnishment following notice of bankruptcy and discharge.

9th Circuit, California, California Eastern District

February 10, 2020

Fraudulent Transfer Damages Limited to Creditors’ Total Claims

Delaware’s Judge Owens won’t allow perpetrators of a fraudulent transfer to benefit from avoiding the transfer.

3rd Circuit, Delaware

February 07, 2020

First Circuit Reverses the BAP for Fact-Finding on Appeal

First Circuit requires detailed fact-finding by the bankruptcy court on the credibility of witnesses and the elements of nondischargeability for false representations.

1st Circuit

February 06, 2020

Lender and Servicer Held Liable for Making False Claim for Real Estate Taxes

Judge Rodriguez holds servicer and lender liable under Rule 3002.1 and the FDCPA for making a claim for unpaid real estate taxes that had been paid.

5th Circuit, Texas, Texas Southern District

February 05, 2020

Stay Violation Order Is Final Even Before Attorneys’ Fees Are Awarded, Circuit Says

First Circuit rules that an order finding a stay violation must be appealed before the bankruptcy court grants an award of attorneys’ fees.

1st Circuit

February 04, 2020

First Circuit’s Traditional Approach to Section 552 Cuts Off Bondholders’ Liens

Employer contributions to Puerto Rico’s retirement system did not qualify as ‘special revenues,’ with the result that bondholders’ liens were cut off on the filing date.

1st Circuit

February 03, 2020

Courts Deeply Split on Social Security Benefits in the Chapter 13 ‘Abuse’ Test

Michigan judges disagree about the court’s ability to consider Social Security benefits in deciding whether a chapter plan was proposed in good faith.

6th Circuit, Michigan, Michigan Eastern District

January 31, 2020

U.S. Receivership Court Had No Jurisdiction over Foreign Liquidators

District judge decides that he lacked jurisdiction to enforce a cross-border protocol against foreign liquidators.

5th Circuit, Texas, Texas Northern District

January 30, 2020

Another Court Approves an Arrangement for Paying Most Chapter 7 Fees After Filing

Careful drafting and copious documentation are required for a bifurcated fee arrangement to pass muster in chapter 7.

6th Circuit, Kentucky, Kentucky Eastern District