The Eighth Circuit aligned with the Ninth Circuit by holding that postpetition appreciation in a home belongs to creditors when a chapter 13 case converts to chapter 7.
Bucking the weight of authority, a district judge allowed an equity committee to appeal dismissal of a chapter 11 case, where the committee wanted a chapter 11 trustee rather than dismissal.
District court rules that proceeds from a postpetition personal injury claim are ‘additional disposable income’ that ordinarily goes to creditors in a chapter 13 plan.
