Dixon v. LaBarge (In re Dixon)
Feb
17
2006
Ruling
Dismissal was affirmed since the debtor failed to show exigent circumstances to warrant granting a waiver of the prefiling credit counseling requirement.
Procedural posture
Appellant bankruptcy debtor filed his bankruptcy petition with a certification that the debtor was unable to obtain debt counseling prior to filing the petition, as required by 11 U.S.C. § 109(h), since a foreclosure sale of his residence was scheduled for the day after the petition was filed. The debtor appealed the order of the Bankruptcy Court for the Eastern District of Missouri which dismissed the debtor's case.
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