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§ 1325(a)(5)

Drive Fin. Servs. LP v. Jordan

Ruling
Till case remains binding precedent under BAPCPA regarding application of prime-plus interest rate.
Procedural posture

Appellant creditor sought a direct appeal under 28 U.S.C.S. § 158(d)(2) of orders of the United States Bankruptcy Court for the Eastern District of Texas amending and confirming a chapter 13 bankruptcy plan submitted by appellee debtors, which provided for interest on the creditor's secured claim on the debtors' truck at a "prime-plus" interest rate pursuant to the cram down provision of 11 U.S.C.S. § 1325(a)(5)(B).

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Court :
Judge or Jurisdiction information not available
Consumer opinion summary, case decided on March 12, 2008 , LexisNexis #0408-021

In re Wallace

Ruling
Chapter 13 plan calling for balloon payment to creditor whose claim was secured by real property could not be confirmed.
Procedural posture

A creditor filed an objection, pursuant to 11 U.S.C. § 1325(a)(5)(B)(iii), to the individual debtors'chapter 13 plan.

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Consumer opinion summary, case decided on November 12, 2007 , LexisNexis #0108-128

In re Garcia

Ruling
Release of lien language could not be included in chapter 13 plan.
Procedural posture

A debtor's chapter 13 plan provided a mechanism for creditors secured by lien notations on certificates of title to release their liens under 11 U.S.C. § 1325(a)(5)(B)(i) upon either the debtor's payment of the entire indebtedness owed to the creditor or an entry of discharge under 11 U.S.C. § 1328. A creditor opposed confirmation of the plan in light of the release provision.

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Consumer opinion summary, case decided on November 09, 2007 , LexisNexis #1207-024

In re Lilly

Ruling
Chapter 13 debtor not entitled to discharge could confirm plan paying Till rate of interest on "910" claim.
Procedural posture

Claimant creditor objected to confirmation of debtor's Amended Chapter 13 Plan. At issue was whether the lien retention provision added by the Bankruptcy Abuse Prevention and Consumer Protection Act of 2005 ("BAPCPA") to 11 U.S.C. § 1325(a)(5)(B)(i) prevented a chapter 13 debtor who was not entitled to a discharge from modifying the interest rate on a secured claim and, if permitted, the post-bankruptcy effect of such modification.

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Consumer opinion summary, case decided on October 30, 2007 , LexisNexis #1207-060

In re Luckett

Ruling
Plan proposing "adequate protection payments" followed by a balloon payment could not be confirmed.
Procedural posture

A chapter 13 trustee and a secured creditor filed objections to confirmation of the debtors'plan. The plan proposed to reduce and fix the creditor's interest on its claim, to provide the creditor with adequate protection payments for the life of the plan, and to make a balloon payment to pay the secured creditor in full.

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Consumer opinion summary, case decided on October 24, 2007 , LexisNexis #1107-122

In re Erwin

Ruling
Equal payment provision not directed at payments by trustee to secured creditors.
Procedural posture

The debtors moved for confirmation of their amended chapter 13 plan. A secured creditor objected on the basis that the plan failed to provide for its secured claim to be paid in equal monthly payments. The issue was whether the trustee could continue to pay debtors'attorney fees on an accelerated basis despite the resulting increase in secured creditor payments once the attorney was fully paid.

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Consumer opinion summary, case decided on October 01, 2007 , LexisNexis #1107-016

In re Hopkins

Ruling
Neither payments nor interest rates for secured debts on "910" vehicles are dependent on original contract but rather determined by plan and Till rate of interest.
Procedural posture

The debtor moved for confirmation of her chapter 13 plan. Creditor filed an objection.

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opinion summary, case decided on July 10, 2007 , LexisNexis #0807-054

Royals v. Massey (In re Denton)

Ruling
Trustee was not liable for overpayments to secured creditors.
Procedural posture

Movant counsel for a bankruptcy debtor asserted that the bankruptcy trustee made errors in disbursing money under a bankruptcy debtor's chapter 13 plan, which resulted in a shortfall of money available to pay counsel's fees under the plan. Counsel moved to hold the debtor in contempt.

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opinion summary, case decided on June 12, 2007 , LexisNexis #0707-085

In re Marshall

Ruling
Till rate of interest, not contract rate, applied to claim secured by motor vehicle purchased just prior to petition date.
Procedural posture

Creditor filed an objection to debtors'proposed chapter 13 plan. In support of its objection, the creditor contended that it was bad faith, per se, for the debtors to have purchase a vehicle 40 days before bankruptcy, fail to make any prepetition payments, and seek to reduce the contract rate of interest in a chapter 13 plan.

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opinion summary, case decided on June 11, 2007 , LexisNexis #0707-086

In re Rodriguez

Ruling
Modification of confirmed plan denied due to debtor's inability to provide for payment of full value of collateral.
Procedural posture

Debtor moved for an order modifying her chapter 13 plan to change both the classification and the treatment of a creditor's claim therein, which claim was secured by debtor's residence, a manufactured home. By separate motion, the creditor sought an order lifting the automatic stay.

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opinion summary, case decided on May 24, 2007 , LexisNexis #0707-015