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§ 1322(b)(2)

Harris v. Amerifirst Home Improvement Fin. Co.

Ruling
One half of second line on property jointly owned by chapter 13 debtor with non-debtor grandson could be avoided.
Procedural posture

Chapter 13 debtor filed an adversary complaint against creditor mortgagee, requesting a determination of the validity and extent of the creditor's second mortgage lien pursuant to 11 U.S.C.S. §§ 506(d), 522(f), and 1322(b)(2).

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Consumer opinion summary, case decided on April 26, 2013 , LexisNexis #0513-137

Hamilton v. Partners for Payment Relief De III LLC (In re Hamilton)

Ruling
Second mortgage at least partially secured by debtor's residence could not be modified or avoided.
Procedural posture

Bankruptcy debtor brought an adversary proceeding against creditor which held a second priority mortgage against the debtor's residence, seeking to avoid the creditor's lien as wholly unsecured. The creditor moved for summary judgment, and the debtor did not respond to the motion.

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Consumer opinion summary, case decided on April 22, 2013 , LexisNexis #0513-067

In re Buster

Ruling
Third mortgage could not be stripped off as value of residence exceeded debt after second mortgage was stripped off.
Procedural posture

Debtors declared chapter 13 bankruptcy and sought an order allowing them to "strip off" a second mortgage and a third mortgage which two banks held on their residence. The court allowed the debtors to strip off the second mortgage; however, a bank that held both the first mortgage and the third mortgage on the debtors' residence filed an objection to the debtors' motion. The court held a hearing on the debtors' motion and the bank's objection.

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Consumer opinion summary, case decided on March 26, 2013 , LexisNexis #0413-096

Aumiller v. GMAC Mortg. LLC (In re Aumiller)

Ruling
Wholly unsecured second lien could be stripped off and avoided upon successful completion of plan.
Procedural posture

Chapter 13 debtors filed a complaint against creditor to avoid the creditor's junior lien on their real property. The debtors moved for summary judgment.

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Consumer opinion summary, case decided on March 26, 2013 , LexisNexis #0413-097

Seidle v. Sovereign Bank (In re Seidle)

Ruling
Debtor could not strip off partially secured second lien.
Procedural posture

Chapter 13 debtor filed an adversary proceeding against three banks and various judgment creditors, seeking a judgment determining the priority of liens defendants placed on his residence and orders allowing him to strip off liens that were unsecured. Two banks that were named as defendants agreed to submit their claims that their lien had priority to mediation.

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Consumer opinion summary, case decided on March 06, 2013 , LexisNexis #0313-132

In re Kelly

Ruling
Confirmation denied due to improper modification of loan on rented property.
Procedural posture

Chapter 13 debtors' plan contained language that attempted to cram down the amount owed on the mortgage on the property in which they lived. The creditor objected, contending that the amounts owed on that property could not be crammed down pursuant to 11 U.S.C.S. § 1322(b)(2).

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Consumer opinion summary, case decided on February 19, 2013 , LexisNexis #0313-064

Rozinski v. ANB Bank (In re Rozinski)

Ruling
Bank's lien could be avoided where debtor met burden of proving residence was worth less than amount owed.
Procedural posture

Debtors filed a petition under chapter 13 of the Bankruptcy Code and proposed a plan for paying their debts which modified the value of their residence and treated a debt they owed a bank on a home equity line of credit as unsecured. The debtors filed a motion which asked the court to determine the value of their residence pursuant to 11 U.S.C.S. § 506(a), to find that a claim the bank filed against their bankruptcy estate was unsecured.

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Consumer opinion summary, case decided on February 12, 2013 , LexisNexis #0313-028

In re Vidal

Ruling
Debtors could not propose to strip down junior liens in plan without filing adversary proceedings to determine is liens were unsecured.
Procedural posture

Several chapter 13 debtors who were represented by the same attorney filed bankruptcy plans which proposed to strip off junior liens creditors held on each debtor's principal residence at a "to-be-commenced" adversary proceeding. A chapter 13 trustee who was appointed to administer the debtors' plans filed an objection to confirmation of each plan.

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Consumer opinion summary, case decided on February 05, 2013 , LexisNexis #0213-133

Hatfield v. CitiFinancial Inc. (In re Hatfield)

Ruling
Wholly unsecured junior lien could be "stripped off" upon completion of chapter 13 plan.
Procedural posture

A chapter 13 debtor moved for summary judgment on an adversary complaint that sought an order allowing her to avoid a junior lien on debtor's residential real property on the basis that the lien was wholly unsecured and thus was properly "stripped off" under 11 U.S.C.S. § 1322(b)(2) and 11 U.S.C.S. § 506(a). Lienholder did not appear in opposition to the motion.

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Consumer opinion summary, case decided on January 28, 2013 , LexisNexis #0213-098

Robinson v. Bank of America (In re Robinson)

Ruling
Modification of mortgage on one unit of multi-unit dwelling could be allowed.
Procedural posture

A chapter 13 debtor filed an adversary proceeding pursuant to 11 U.S.C.S. § 506(a) and Fed. R. Bankr. P. 3012 against defendant creditor seeking to determine the validity of the creditor's lien on the debtor's property.

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Consumer opinion summary, case decided on January 28, 2013 , LexisNexis #0313-029