Discovery sanctions are dischargeable under Section 523(a)(7), even when incorporated into a bar disciplinary suspension.

A claim must be disallowed based on the invalidity of the debt before the associated lien can be voided under Section 506(d), the Ninth Circuit ruled in upholding the BAP.

Judge Klein’s opinion reads like an amicus brief urging the Supreme Court to grant ‘cert’ and resolve a circuit split by taking sides with the majority on Section 362(c)(3)(A).

Majority on Ninth Circuit panel believe that having previously extended a deadline allowed the invocation of “excusable neglect” to extend the deadline again after it expired.

Two recent decisions by the 9th Circuit BAP seem in conflict on a chapter 13 debtor’s ability to retain appreciation in the value of assets.

ABI Consumer Commission recommended that ‘comfort orders’ be obtained through motion practice, not adversary proceedings.

If a creditor objects to chapter 13 eligibility in good faith, the court may look behind the debtor’s schedules to decide whether the debt exceeds the cap.

Permanently reducing the claim by the appraised value without a backstop means the creditor isn’t receiving the ‘indubitable equivalent,’ BAP says.

Ninth Circuit assumed that transferred property must remain property of the estate after conversion from ‘13’ to ‘7’ before the chapter 7 trustee can avoid an unauthorized transfer under Section 549.

Taggart left open the question of whether the ‘no objectively reasonable basis’ standard for discharge violations also applies to contempt of the automatic stay.