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§ 1322(b)(2)

In re Clardy

Ruling
Second mortgage partially secured by equity was not subject to modification in plan.
Procedural posture

Debtors filed a petition under chapter 13 and a proposed plan for paying their creditors. A corporation that held a second mortgage on the debtors'residence opposed the debtors'motion for confirmation of their plan. The case was tried by the court.

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opinion summary, case decided on June 12, 2007 , LexisNexis #0707-084

In re Davis

Ruling
Secured claim in mobile home protected by anti-modification provision.
Procedural posture

The debtors filed for relief under chapter 13 and filed an amended chapter 13 plan. The creditor, who had a perfected mortgage in the debtors'real property and a perfected security interest in the debtors'mobile home, filed an objection to confirmation of the amended plan.

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opinion summary, case decided on May 24, 2007 , LexisNexis #0707-012

In re Dominique

Ruling
Lender waived anti-modification rights by failing to provide debtor with annual notices of escrow increases.
Procedural posture

Chapter 13 debtors moved to determine that postpetition escrow account increases raised by its primary residential lender were dischargeable. The lender asserted that the postpetition obligations secured by debtors'residence could not be modified under 11 U.S.C. § 1322(b)(2), although the lender had not given annual escrow notices to debtors as required by 24 C.F.R. § 3500.17(f).

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opinion summary, case decided on May 14, 2007 , LexisNexis #0607-138

Cox v. Beneficial Neb. Inc. (In re Cox)

Ruling
Debtors could strip of wholly unsecured lien on real property pursuant to chapter 13 plan.
Procedural posture

The debtors filed a motion to determine the status of the automatic stay in their chapter 13 bankruptcy case.

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opinion summary, case decided on April 09, 2007 , LexisNexis #0507-030

Eastern Savings Bank v. LaFata (In re LaFata)

Ruling
Banktuptcy court properly bifurcated mortgage claim secured by two lots where home was mistakenly built on dividing property line.
Procedural posture

Before the court were two appeals. In the first, appellant bank challenged an order of the District Court for the District Court of Massachusetts which allowed the bifurcation of appellee debtor's chapter 13 claims. The bank also appealed an order of the Bankruptcy Appellate Panel of the First Circuit (Panel) which denied its Fed. R. Civ. P. 60(b) motion seeking reconsideration of three orders decided in the debtor's favor.

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Court :
Judge or Jurisdiction information not available
opinion summary, case decided on April 03, 2007 , LexisNexis #0507-068

In re Cartwright

Ruling
Confirmation denied as state court reformation of mortgage to cover two tracts of land prevented debtor from proposing to make payments on one tract and surrender the other.
Procedural posture

A secured creditor objected to confirmation of a debtor's proposed first amended plan of reorganization under chapter 13.

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opinion summary, case decided on March 23, 2007 , LexisNexis #0507-083

Craig-Likely v. Wells Fargo Home Mortg. (In re Craig-Likely)

Ruling
Mortgage creditor waived right to claim postpetition escrow deficiency due to failure to provide debtor with notice of changes in payments.
Procedural posture

Appellant chapter 13 debtor sought review of an order issued by the bankruptcy court, which denied the debtor's motion to foreclose appellee mortgagee from asserting a postpetition arrearage claim that resulted from a deficiency in the escrow account for insurance premiums and tax payments.

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opinion summary, case decided on March 02, 2007 , LexisNexis #0707-053

In re Turner-Mayo

Ruling
Plan rate of interest controlled over higher note rate where creditor's proof of claim contained the erroneous lower rate but there had been no objection to confirmation.
Procedural posture

Before the court in a chapter 13 case was debtor's objection to a mortgage creditor's Proof of Claim.

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opinion summary, case decided on February 08, 2007 , LexisNexis #0407-031

In re Wegscheid

Ruling
Wholly unsecured creditor's lien could be stripped off upon plan completion.
Procedural posture

The debtor's chapter 13 plan provided that a creditor's second lien would be treated as a general unsecured claim and discharged upon completion of the plan. The debtor completed all plan payments and obtained a discharge. The debtor then filed a motion to avoid the creditor's lien under 11 U.S.C. §§ 506(a) and 1322(b)(2), and the creditor objected to the motion.

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opinion summary, case decided on January 29, 2007 , LexisNexis #0307-067

In re Shepherd

Ruling
Mobile home qualified as "debtor's principal residence" so that anti-modification provisions applied.
Procedural posture

Creditor objected to the confirmation of chapter 13 debtor's plan.

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opinion summary, case decided on November 03, 2006 , LexisNexis #1206-077