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§ 1325(a)(5)(B)

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 Hill

Ruling
Confirmation denied due to debtor's failure to adequately address creditor's lien or equal monthly payments.
Procedural posture

A trustee and an oversecured creditor objected to confirmation of a debtor's chapter 13 plan of reorganization.

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opinion summary, case decided on February 12, 2007 , LexisNexis #0307-119

In re Monochie

Ruling
Confirmation denied due to failure to provide secured creditor with interest over life of plan.
Procedural posture

Debtors filed a chapter 13 plan. The plan included provisions with regard to the secured claim of creditor bank. The bank objected to the provisions of the plan dealing with its claim.

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opinion summary, case decided on November 01, 2006 , LexisNexis #1206-112

In re Nice

Ruling
Cramdown of automobile loan allowed for presumptive replacement value in pre-BAPCPA case.
Procedural posture

Chapter 13 debtor filed a motion pursuant to 11 U.S.C. § 1325(a)(5)(B) to cram down the value of creditor's secured claim against her personal vehicle from $56,600 to $36,050.

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opinion summary, case decided on October 30, 2006 , LexisNexis #1206-140

In re Grunau

Ruling
Plan that extended payment terms on car loan over creditor's objection ordered modified in accordance with Till.
Procedural posture

In the debtors' chapter 13 case, a creditor moved for relief from a confirmation order and for a rehearing on its objection to the chapter 13 plan. The creditor had objected to the plan's restructuring of a repayment plan on the creditor's car loan on the ground that the interest rate was too low.

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opinion summary, case decided on October 04, 2006 , LexisNexis #1106-108