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§ 1322(b)(2)

In re Monson

Ruling
Plan calling for payment of mortgage over course of 57 months confirmed over mortgagee's objection.
Procedural posture

This matter came before the court for an evidentiary hearing on the confirmation of the debtor's amended chapter 13 plan and an objection filed by a mortgagee on the debtor's residence.

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Consumer opinion summary, case decided on December 07, 2009 , LexisNexis #0110-098

In re Finley

Ruling
Debtor could not surrender real property that was not primary residence in full satisfaction of mortgage debt.
Procedural posture

A mortgagee objected to the debtors' chapter 13 plan that proposed to surrender the real property that was not the debtor's principal residence in full satisfaction of the mortgagee's claim.

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Consumer opinion summary, case decided on July 21, 2009 , LexisNexis #0909-096

Reinhardt v. Vanderbilt Mortg. & Fin. Inc. (In re Reinhardt)

Ruling
Security interest in mobile home that was not considered real property under state law could be modified.
Procedural posture

Appellee debtors, filed for bankruptcy protection under chapter 13 and sought a cramdown of appellant creditor's secured claim. The creditor filed an objection. The United States Bankruptcy Court for the Southern District of Ohio overruled the objection and confirmed debtors' proposed plan. The creditor appealed.

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Court :
Judge or Jurisdiction information not available
Consumer opinion summary, case decided on April 29, 2009 , LexisNexis #0609-092

Jordan v. Greentree Consumer Disc. Co. (In re Jordan)

Ruling
Security interest in mobile home was subject to modification.
Procedural posture

Chapter 13 debtors sued defendant creditor, seeking to modify the creditor's rights pursuant to 11 U.S.C.S. § 506(d). The parties filed cross-motions for summary judgment.

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Consumer opinion summary, case decided on March 27, 2009 , LexisNexis #0509-020

Ennis v. Green Tree Servicing LLC (In re Ennis)

Ruling
Claim secured by mobile home which was personal property rather than real property under state law was not protected from modification.
Procedural posture

Appellant debtors sought review of an order of the Bankruptcy Court for the Western District of Virginia sustaining appellee creditor's objection to the debtors' chapter 13 plan. The bankruptcy court held that the creditor's claim, which was secured by a lien on the debtors' mobile home, was protected under 11 U.S.C.S. § 1322(b)(2) from modification because the mobile home was real property that was the debtors' principal residence.

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Court :
Judge or Jurisdiction information not available
Consumer opinion summary, case decided on February 25, 2009 , LexisNexis #0409-015

In re Booth

Ruling
Plan could not preclude mortgage creditor's postpetition fees but could require application of payments as though loan was current.
Procedural posture

A bankruptcy debtor's chapter 13 plan included provisions which precluded the debtor's mortgage creditor from charging postpetition fees, and required the creditor to apply plan payments by deeming any pre-petition arrearages to be contractually current and notify the debtor and others concerning changes in payment amount. The creditor challenged these plan provisions and objected to confirmation of the plan.

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Consumer opinion summary, case decided on January 14, 2009 , LexisNexis #0209-089

In re Dunn

Ruling
Plan proposing sale of property as cure for prepetition mortgage default did not impermissibly modify lender's rights.
Procedural posture

Debtors filed a motion to confirm their chapter 13 plan, and a creditor bank objected to plan confirmation on the ground that the proposed plan impermissibly modified its rights in violation of 11 U.S.C.S. § 1322(b)(2). The bank also filed a motion for adequate protection payments pending confirmation.

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Consumer opinion summary, case decided on January 09, 2009 , LexisNexis #0209-090

In re Patton

Ruling
Plan could require mortgage creditors to apply payments as if prepetition default had not occurred.
Procedural posture

Chapter 13 debtors filed plans containing language objectionable to secured creditors, all of whom were home lenders. The plans' proposed language provided that the payments would be applied to the debtors' mortgage accounts as if the accounts were current and no prepetition defaults existed on the petition dates, and the creditors argued that those provisions impermissibly modified their secured liens in violation of 11 U.S.C.S. § 1322(b)(2).

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Consumer opinion summary, case decided on November 19, 2008 , LexisNexis #0209-056

Armstrong v. Lasalle Bank Natl Assn

Ruling
Bank could not claim retroactive postpetition, postconfirmation interest payment change where notice was not timely filed.
Procedural posture

Creditor filed a notice of post-petition payment change which provided for multiple payment changes over a period of years on the debtor's mortgage. The debtor filed an objection to the notice as being late filed and untimely and requested a finding that the creditor was limited to the monthly payment as provided for in the amended chapter 13 plan.

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Consumer opinion summary, case decided on October 08, 2008 , LexisNexis #1108-033

In re McCullum

Ruling
Intention to sell home did not entitle debtors to modify second mortgage nor did inclusion of fixtures and rents as additional security.
Procedural posture

Debtors filed a petition under chapter 13 of the Bankruptcy Code, and a bank that held a second mortgage on the debtors' residence filed a proof of secured claim in the amount of $ 66,547. The debtors filed a motion to value the bank's claim, contending that the claim should be split into a secured claim in the amount of $ 45,842, and an unsecured claim in the amount of $ 20,704, pursuant to 11 U.S.C.S. § 506(a). The bank opposed the motion.

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Consumer opinion summary, case decided on September 23, 2008 , LexisNexis #1108-051