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§ 1322(b)(2)

Stallard v. Charter One (In re Stallard)

Ruling
Wholly unsecured junior lien could be stripped off if debtor fully performed under confirmed plan.
Procedural posture

Debtors brought this action pursuant to 11 U.S.C.S. § 506(a), (d), and Fed. R. Bankr. P. 3012, 7001(2) seeking to determine the value of defendant creditor's interest in debtor's residential real estate and to determine the status of the creditor's claim. The matter came before the court for hearing upon proper notice.

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Consumer opinion summary, case decided on October 02, 2012 , LexisNexis #1112-133

In re Smith

Ruling
Fact that non-debtor spouse did not sign mortgage on entireties property did not justify reduction of mortgage debt in plan, which could not be confirmed.
Procedural posture

A bankruptcy debtor proposed a plan which provided for full payment of a creditor's mortgage against the debtor's residence which the debtor substantially reduced because the debtor's spouse as a co-owner of the residence did not execute the mortgage. The creditor objected to confirmation of the debtor's plan.

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Consumer opinion summary, case decided on September 25, 2012 , LexisNexis #1012-097

In re Hymel

Ruling
Creditor's claim in increased amount from that claimed in stipulation disallowed on debtor's objection.
Procedural posture

After a creditor filed a stay relief motion alleging a payment default, the parties entered into a stipulation. The chapter 11 debtor objected to the creditor's claim in an increased amount, contending that the stipulation addressed and resolved the question of postpetition arrearages.

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Consumer opinion summary, case decided on September 13, 2012 , LexisNexis #1012-029

In re Fox

Ruling
Objection to confirmation sustained where there was value securing creditor's lien which plan proposed to treat as unsecured.
Procedural posture

Before the court was a creditor's objection to debtors' chapter 13 plan.

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Consumer opinion summary, case decided on September 04, 2012 , LexisNexis #1012-098

Wallingford v. Green Tree Servicing LLC

Ruling
Sustaining of objection to confirmation overruled where title to mobile home securing lien creditor claimed was protected from modification had never been surrendered.
Procedural posture

Appellant debtors challenged orders of the United States Bankruptcy Court for the Southern District of Ohio, which sustained an objection to confirmation of their chapter 13 Plan and denied their motion for reconsideration.

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Consumer opinion summary, case decided on August 31, 2012 , LexisNexis #1012-030

Hernandez-Torres v. Charter One Bank (In re Hernandez-Torres)

Ruling
Debtor could strip off lien that exceeded value of residential property.
Procedural posture

Plaintiff chapter 13 debtors filed a complaint pursuant to 11 U.S.C.S. § 506(a) and (d) and Fed. R. Bankr. P. 3012 and 7001(2) against defendant bank, seeking to determine the value of the bank's interest in the debtors' residential real estate and to determine the status of the bank's claim.

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Consumer opinion summary, case decided on August 13, 2012 , LexisNexis #0912-029

Bynum v. CitiMortgage Inc. (In re Bynum)

Ruling
Deed of trust did not create security interest in escrow funds but solely against residence, precluding modification.
Procedural posture

Plaintiff bankruptcy debtors brought an adversary proceeding against defendant creditor secured by a deed of trust against the debtors' principal residence, seeking a valuation of the residence for purposes of modifying the creditor's secured claim into secured and unsecured claims. The creditor moved to dismiss the complaint.

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Consumer opinion summary, case decided on July 20, 2012 , LexisNexis #0812-096

Poe v. Wells Fargo Bank (In re Poe)

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

Plaintiffs, chapter 13 debtors, filed an adversary proceeding against defendant creditor to avoid a junior lien on their real property under 11 U.S.C.S. § 1322(b)(2), contending that the junior lien was wholly unsecured under 11 U.S.C.S. § 506(a). They sought summary judgment.

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Consumer opinion summary, case decided on July 09, 2012 , LexisNexis #0912-030

Mullins v. Wells Fargo Bank (In re Mullins)

Ruling
Secured claim based on unambiguous deed of trust could not be modified.
Procedural posture

Chapter 13 debtors, who owned and resided in a residence, alleged that the value of the residence does not exceed $41,000, and moved to modify the secured claim of defendant mortgagee, by reducing the value of its secured claim to $41,000, pursuant to 11 U.S.C.S. § 1322(b)(2).

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Consumer opinion summary, case decided on July 03, 2012 , LexisNexis #0712-136

In re Hinkle

Ruling
Confirmation denied where modification of undersecured claim secured by residential and commercial property would not be cured through plan.
Procedural posture

Debtor filed a chapter 13 bankruptcy petition and proposed plan. Timely objections to confirmation of the Plan were filed by creditor bank, holder of an oversecured claim.

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Consumer opinion summary, case decided on July 02, 2012 , LexisNexis #0712-137