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§ 109(h)

Rivett, In re--Rivett v. Carlson

Ruling
Court found that the issue of late filing fee payments was immaterial because the lack of credit counseling certification alone rendered debtor ineligible. (8th Cir.)
Issue(s)
Who May Be a Debtor; Mandatory Credit Counseling.

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Consumer opinion summary, case decided on July 28, 2025 , LexisNexis #0925-078

Salee Amina Mohammed, In re

Ruling
Chapter 13 case properly dismissed as debtor failed to comply with credit counseling requirement and there were no exceptional circumstances justifying relief. (Bankr. D. Utah)
Issue(s)
Who May Be a Debtor; Mandatory Credit Counseling.

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Consumer opinion summary, case decided on May 16, 2025 , LexisNexis #0725-051

Muszynski v. Millennium Funding, Inc.

Ruling
Bankruptcy court did not abuse its discretion in finding that the debtor failed to describe exigent circumstances meriting a waiver of the credit counseling requirement. (B.A.P. 1st Cir.)
Issue(s)
Who May Be a Debtor; Mandatory Credit Counseling.

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Consumer opinion summary, case decided on March 07, 2025 , LexisNexis #0525-026

Key, In re

Ruling
Debtor's voluntary petition for Chapter 7 relief was dismissed where she did not receive acredit counseling briefing until three days after filing the bankruptcy petition. (Bankr. E.D.Mich.)
Issue(s)
Who May Be a Debtor; Mandatory Credit Counseling.

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Consumer opinion summary, case decided on April 29, 2024 , LexisNexis #0724-001

Johnson, In re

Ruling
Debtor's request to seal court records was denied as he failed to show good cause to overcomethe presumption in favor of public access. (Bankr. S.D. Ga.)
Issue(s)
Who May Be a Debtor; Mandatory Credit Counseling; Exemption.

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Consumer opinion summary, case decided on December 26, 2023 , LexisNexis #0224-076

Muszynski, In re

Ruling
Case dismissed as debtor did not comply with the credit counseling requirement.(Bankr. D.P.R.)
Issue(s)
Who May Be a Debtor; Mandatory Credit Counseling.

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:
Judge or Jurisdiction information not available
Consumer opinion summary, case decided on June 30, 2023 , LexisNexis #0724-076

Thomason, In re

Ruling
Extension of the automatic stay was not appropriate as debtor had not demonstrated by clearand convincing evidence that the second bankruptcy case was filed in good faith. (Bankr. D.Idaho)
Issue(s)
Who May Be a Debtor; Mandatory Credit Counseling.

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Consumer opinion summary, case decided on December 06, 2022 , LexisNexis #0223-001

Ellenburg, In re

Ruling
Case dismissed where debtor who was not eligible filed for Chapter 7 relief and caused anunreasonable delay that was prejudicial to creditors. (Bankr. D.S.C.)
Issue(s)
Who May Be a Debtor; Mandatory Credit Counseling; Approved Nonprofit Agency.

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:
Judge or Jurisdiction information not available
Consumer opinion summary, case decided on May 18, 2022 , LexisNexis #0722-027

Hill, In re

Ruling
Debtor's case was dismissed as his certificate of credit counseling was insufficient as he didnot file a certificate or a motion to approve his certification of exigent circumstances. (Bankr.E.D. Mich.)
Issue(s)
Who May Be a Debtor; Mandatory Credit Counseling; Approved Nonprofit Agency.

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Consumer opinion summary, case decided on March 09, 2022 , LexisNexis #0522-026

Bulger, In re

Ruling
Motion for stay and injunction pending appeal of dismissal for failure to obtain requiredcredit counseling denied absent probable likelihood of success. (Bankr. M.D. Ala.)
Issue(s)
Who May Be a Debtor; Mandatory Credit Counseling.

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Consumer opinion summary, case decided on February 04, 2022 , LexisNexis #0322-077