Skip to main content

§ 348(f)

In re Easley-Brooks

Ruling
Debtor could reopen case to allow trustee to prosecute medical malpractice claim, undisclosed prior to conversion, for benefit of creditors and estate.
Procedural posture

Debtor moved pursuant to 11 U.S.C.S. § 350(b) and Fed. R. Bankr. P. 5010 to reopen her chapter 7 case to include a medical malpractice action in her schedule of assets and to enable the chapter 7 trustee to prosecute the malpractice action for the benefit of creditors and the debtor. Defendant in the malpractice action objected.

ABI Membership is required to access the full summary of In re Easley-Brooks 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 25, 2013 , LexisNexis #0313-079

Lentz v. Myers (In re Myers)

Ruling
All property held by debtor as of date of bad faith conversion to chapter 7 was property of the estate.
Procedural posture

The chapter 7 trustee sought an adjudication that certain legal causes of action pursued by defendants, debtors and their subsequently-formed corporation against third-parties in a district court action were property of the debtors' chapter 7 bankruptcy estate, and whether the corporation was a successor in interest to the debtors.

ABI Membership is required to access the full summary of Lentz v. Myers (In re Myers) 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 14, 2013 , LexisNexis #0313-105

In re Wiggins

Ruling
Conversion to chapter 7 was in bad faith due to spending of estate funds while chapter 13 case was still pending.
Procedural posture

Following debtors' conversion of their case from chapter 13 to chapter 7, the chapter 7 trustee moved to compel turnover of property of the estate, including funds and a one-half interest in real property inherited by one debtor, and asserted that debtors had made the conversion in bad faith.

ABI Membership is required to access the full summary of In re Wiggins 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, 2012 , LexisNexis #1012-042

In re Robinson

Ruling
Postpetition accumulated equity in vehicles was not property of the estate.
Procedural posture

A chapter 7 trustee filed a motion to compel debtors to turn over property. The trustee contended that the debtors' post-petition accumulated equity in their vehicles, to the extent it exceeded any applicable exemptions, was property of the estate pursuant to 11 U.S.C.S. § 348(f).

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

Consumer opinion summary, case decided on May 03, 2012 , LexisNexis #0612-004

Warfield v. Salazar (In re Salazar)

Ruling
Refund received and spent prior to conversion from chapter 13 to chapter 7 properly held not to be property of the estate.
Procedural posture

Trustee challenged a ruling of the U.S. Bankruptcy Court for the District of Arizona denying a motion to compel appellee debtors, who had filed a chapter 13 that was converted to a chapter 7, to pay over funds received as a tax refund during the pendency of the chapter 13 case. Debtors had successfully claimed that as they had spent the funds, the refund no longer constituted "estate property" per 11 U.S.C.S. § 348(f)(1)(A).

ABI Membership is required to access the full summary of Warfield v. Salazar (In re Salazar) 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 April 05, 2012 , LexisNexis #0512-114

In re McGregor

Ruling
Determination in chapter 13 case that lien was unsecured had no binding effect after conversion to chapter 7.
Procedural posture

In a prior bankruptcy case, bankruptcy debtors converted their chapter 13 case in which a creditor's claim was deemed unsecured and the debtors received a chapter 7 discharge. The debtors objected to the creditor's secured claim in their instant chapter 13 case on the ground that the claim was unsecured and discharged in their prior case.

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

Consumer opinion summary, case decided on June 02, 2011 , LexisNexis #0711-037

In re Lang

Ruling
Debtor in converted chapter 7 case not required to turn over difference between current value of vehicle and value at date of original filing under chapter 13.
Procedural posture

A Chapter 7 trustee moved to compel the debtor to turn over $7,250, which was the non-exempt value of an automobile as of the date of the filing of the case in Chapter 13. The central issue was whether the debtor had to account for that value even after the conversion of her case to Chapter 7.

ABI Membership is required to access the full summary of In re Lang 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 17, 2010 , LexisNexis #1010-135

In re Grein

Ruling
Assets not subject to turnover after reconversion from chapter 13 back to chapter 7 due to benefit received by unsecured creditors in chapter 13.
Procedural posture

In a chapter 7 proceeding, the trustee moved to compel turnover of non- exempt portions of debtors' accounts receivable and equity in their automobile. The issues were whether the assets generated from a disposition of assets belonging to debtors during a chapter 13 case were property of a chapter 7 estate after conversion, and whether debtors had to surrender the value of that property to the chapter 7 trustee following conversion.

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

Consumer opinion summary, case decided on August 09, 2010 , LexisNexis #1010-076

Mullican v. Moser

Ruling
IRA became property of the debtors' estate upon bad faith conversion to chapter 7.
Procedural posture

Appellant debtors challenged a judgment of the United States Bankruptcy Court for the Eastern District of Texas, which found that the debtors had converted their case from chapter 13 to chapter 7 in bad faith, and that a large IRA they inherited had become property of the bankruptcy estate on the conversion (not petition) date. Appellee, the chapter 7 trustee, cross-appealed as to the date the IRA became property of the bankruptcy estate.

ABI Membership is required to access the full summary of Mullican v. Moser Please sign in if you are already an ABI member, or otherwise you may Become an ABI Member

Consumer opinion summary, case decided on August 04, 2009 , LexisNexis #0909-064

Adams v. Bostick (In re Bostick)

Ruling
Post-chapter 13 petition lottery winnings were not part of estate after conversion to chapter 7 by trustee.
Procedural posture

The United States trustee moved for the entry of a default judgment denying the debtor a discharge in her converted chapter 7 case, pursuant to 11 U.S.C.S. § 727(a). The issue was whether property in the form of lottery winnings won after the filing of the chapter 13 petition was property of the chapter 7 estate within the purview of 11 U.S.C.S. § 727(a)(2)(B).

ABI Membership is required to access the full summary of Adams v. Bostick (In re Bostick) 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 02, 2009 , LexisNexis #0609-037