Skip to main content

§ 1322(b)(2)

In re Wilcox

Ruling
Modification of second mortgage that reflected prior agreement did not prevent confirmation of plan.
Procedural posture

Pending before the court was the debtor's second amended chapter 13 plan including valuation of collateral and classification of claims and the chapter 13 trustee's objection to confirmation of the plan pursuant to 11 U.S.C.S. § 1322(b)(2).

ABI Membership is required to access the full summary of In re Wilcox Please sign in if you are already an ABI member, or otherwise you may Become an ABI Member

Consumer opinion summary, case decided on September 07, 2010 , LexisNexis #1010-025

In re Golash

Ruling
Interest rate could be modified where loan would mature before completion of plan which would pay present value of claim in equal monthly installments.
Procedural posture

A creditor filed an objection to confirmation of a chapter 13 plan on the grounds that it sought to modify the contractual interest rate of a mortgage that the creditor held on the debtor's principal residence in violation of 11 U.S.C.S. § 1322(b)(2).

ABI Membership is required to access the full summary of In re Golash Please sign in if you are already an ABI member, or otherwise you may Become an ABI Member

Consumer opinion summary, case decided on April 12, 2010 , LexisNexis #0610-102

In re Burnett

Ruling
Completion of chapter 13 plan to discharge was not a requirement for stripping junior lien.
Procedural posture

The chapter 13 trustee and the debtor's counsel disagreed over the terms to be included in the debtor's confirmation order. The debtor argued she was not required to complete the plan and obtain a discharge to be allowed to strip off a junior trust deed lien.

ABI Membership is required to access the full summary of In re Burnett Please sign in if you are already an ABI member, or otherwise you may Become an ABI Member

Consumer opinion summary, case decided on April 02, 2010 , LexisNexis #0610-131

In re Aubuchon

Ruling
Avoidance of second deed of trust denied given sufficient equity in subject property.
Procedural posture

Debtors filed a voluntary petition under chapter 13. Debtors moved for valuation of their residence and for avoidance of a second deed of trust held by a credit union.

ABI Membership is required to access the full summary of In re Aubuchon Please sign in if you are already an ABI member, or otherwise you may Become an ABI Member

Consumer opinion summary, case decided on March 04, 2010 , LexisNexis #0510-099

In re Bradsher

Ruling
In state where escrow funds were considered personal property, bank's claim was not secured solely by real property that was debtor's residence and could be modified.
Procedural posture

A bank creditor objected to confirmation of the chapter 13 plan proposed by debtor on the ground that debtor was attempting to modify its secured claim in contravention of the anti- modification provision of 11 U.S.C.S. § 1322(b)(2). The creditor also objected to debtor's $ 22,780 valuation of her residence.

ABI Membership is required to access the full summary of In re Bradsher Please sign in if you are already an ABI member, or otherwise you may Become an ABI Member

Consumer opinion summary, case decided on February 16, 2010 , LexisNexis #0410-135

In re Vallejo

Ruling
Deed of trust voided where there was no equity in subject property.
Procedural posture

Before the court was debtors' motion to value their residence and to avoid the second deed of trust of a creditor. At issue was whether any equity was available to partially secure the second deed of trust, which would bring into play the anti-modification protection of 11 U.S.C.S. § 1322(b)(2).

ABI Membership is required to access the full summary of In re Vallejo Please sign in if you are already an ABI member, or otherwise you may Become an ABI Member

Consumer opinion summary, case decided on February 09, 2010 , LexisNexis #0410-062

Leff v. Herrera (In re Herrera)

Ruling
Additional reporting obligation placed on mortgagees as part of plan were not impermissible modifications.
Procedural posture

Appellee debtors filed separate petitions under chapter 13 of the Bankruptcy Code, and appellant mortgagees filed objections to plans the debtors proposed, claiming that the debtors' use of Bankr. C.D. Cal. Form 3015-1.1A violated the Real Estate Settlement Procedures Act (RESPA) and 11 U.S.C.S. § 1322(b)(2). The U.S. Bankruptcy Court for the Central District of California confirmed the debtors' plans, and the mortgagees appealed.

ABI Membership is required to access the full summary of Leff v. Herrera (In re Herrera) Please sign in if you are already an ABI member, or otherwise you may Become an ABI Member

Court :
Judge or Jurisdiction information not available
Consumer opinion summary, case decided on January 05, 2010 , LexisNexis #0210-098

In re Roemer

Ruling
Debtor could modify claim secured by condominium that was not debtor's primary residence.
Procedural posture

Debtor sought a ruling that her plan could treat the claim of a bank secured by debtor's condominium as secured only to the extent of the value of that property. Pending were debtor's motion for summary judgment, and the bank's motion for summary judgment.

ABI Membership is required to access the full summary of In re Roemer Please sign in if you are already an ABI member, or otherwise you may Become an ABI Member

Consumer opinion summary, case decided on December 28, 2009 , LexisNexis #0210-026

In re Brammer

Ruling
Anti-modification provision did not extend to determine eligibility for chapter 13 relief.
Procedural posture

Before the court was the chapter 13 trustee's motion to dismiss debtors' bankruptcy case with prejudice based on 11 U.S.C.S. §§ 101(30), 109(e), ineligibility and bad faith. The court limited this decision to determining whether grounds existed for dismissing the case based on ineligibility under 11 U.S.C.S. § 109(e)'s debt limitation provision.

ABI Membership is required to access the full summary of In re Brammer Please sign in if you are already an ABI member, or otherwise you may Become an ABI Member

Consumer opinion summary, case decided on December 16, 2009 , LexisNexis #0210-065

Hammond v. Allegheny County Treasurer (In re Hammond)

Ruling
Debtor could redeem property sold at sheriff's sale and strip down local tax liens as part of chapter 13 plan.
Procedural posture

Plaintiff bankruptcy debtor brought an adversary proceeding against defendant local taxing agencies seeking a determination of the secured status of tax liens after the debtor's planned redemption of real property which was sold at a sheriff's sale for unpaid taxes. The agencies contended that the debtor lacked standing to attempt to strip the agencies' tax liens.

ABI Membership is required to access the full summary of Hammond v. Allegheny County Treasurer (In re Hammond) Please sign in if you are already an ABI member, or otherwise you may Become an ABI Member

Consumer opinion summary, case decided on December 15, 2009 , LexisNexis #0110-097