Tyler was applied retroactively because the debtor’s efforts to set aside a tax foreclosure judgment were ‘in the pipeline’ when bankruptcy began.
Aug 2024
Extending statutes of limitations does not affect ‘substantive’ rights, thus the Rules Enabling Act does not preclude a rule from allowing an extension, Judge Julie Manning says.
An inchoate interest in property created by filing a divorce action doesn’t survive dismissal of the divorce action, the Tenth Circuit BAP says.