In re Mercado

The chapter 7 trustee filed an objection to the debtors'purported conversion of their case from a chapter 7 to a chapter 13 claim, asserting that the debtors had acted in bad faith, because they converted nonexempt assets into an alleged exempt homestead when they had debts of at least $50,000. The trustee noted that the Supreme Court's recent ruling in Marrama v. Citizens Bank of Mass. was controlling precedent.