Detroit’s Judge Randon holds that a chapter 13 plan’s five-year duration begins to run from the first payment, not from confirmation.
Eleventh Circuit joins the majority of circuits by holding that unforeseen, changed circumstances are not required to modify a chapter 13 plan.
The Seventh Circuit opinion raises the question of whether (or when) a court may restrict the use of a provision in a chapter 13 plan that Section 1322(b) permits.
