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ABI Journal

1326

Barton Didn’t Stop Creditors from Garnishing a Chapter 13 Trustee After Dismissal

The debtor’s bad faith chapter 13 filings convinced Judge Hall to allow garnishment of funds held by the trustee after dismissal.

First Circuit Dismisses as Moot Even Though the Appeal Dealt with Payment of Money

Dismissal of a chapter 13 case moots an appeal regarding an allegedly erroneous order directing payment of money.

Chapter 13 Trustees Are Paid Even if Dismissal Comes Before Confirmation, BAP Says

The Ninth Circuit BAP joins the minority on an issue that’s headed for the court of appeals.

On Dismissal of a ‘13,’ Barton May (or May Not) Bar Garnishments

Section 1326(a)(2) by itself does not bar garnishment of funds held by a trustee on dismissal before confirmation.