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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.
Since its inception, subchapter V of chapter 11 has been lauded for providing a streamlined path through chapter 11 for smaller chapter 11 debtors without many of the costs associated with “traditional” chapter 11 cases. But before a debtor can elect subchapter V treatment and take advantage of these benefits, the debtor must have less than $7.5 million in total noncontingent, liquidated debts (both secured and unsecured).