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§ 362(a)

In re Cochonour

Ruling
Administrator of decedent's estate violated stay by filing forgery action against debtor.
Procedural posture

A chapter 7 debtor claimed that a decedent's estate and an attorney who represented the estate violated the automatic stay provision of 11 U.S.C. § 362, he filed a motion to impose sanctions, pursuant to 11 U.S.C. § 362(k), on the estate and the attorney. The estate and the attorney opposed the motion.

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opinion summary, case decided on August 02, 2007 , LexisNexis #0807-110

Midkiff v. Lowes Home Ctrs. Inc.

Ruling
Action against store that sold collapsed ladder subject to stay in manufacturer's bankruptcy.
Procedural posture

Plaintiff customer asserted a breach of warranty claim pursuant to the Uniform Commercial Code, Va. Code Ann. §§ 8.01-1 et seq. (2006), against defendant store to recover damages for injuries she sustained when a ladder she purchased from the store collapsed while in use. Before the court was the store's motion for summary judgment or, in the alternative, to stay proceedings pending the outcome of a manufacturer's bankruptcy proceedings.

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opinion summary, case decided on July 30, 2007 , LexisNexis #0807-109

Radcliffe v. International Painters & Allied Trades Ind. Pension Fund (In re Radcliffe)

Ruling
Pension fund's failure to pay debtor regular monthly benefits constituted a willful violation of stay.
Procedural posture

Plaintiff debtor sought a determination against defendant pension fund that actions undertaken by the fund as to pension benefits payable to debtor under a qualified plan constituted a violation of the automatic stay of 11 U.S.C. § 362(a). Pending was a motion of the fund, deemed by the court to request review of matters addressed in the court's March 17, 2007 order prior to entry of final judgment. The fund sought relief from stay.

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opinion summary, case decided on July 19, 2007 , LexisNexis #0907-023

In re Enyedi

Ruling
Dismissal of state court action that was property of the estate violated stay.
Procedural posture

Chapter 7 trustee filed a motion to have a state court dismissal of a lawsuit filed by the debtors declared void ab initio on the grounds that the dismissal order violated the automatic stay under 11 U.S.C. § 362(a)(3), have the defendants in the state court lawsuit assessed compensatory and punitive damages, and attorney fees and costs, based upon their willful violation of the automatic stay.

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opinion summary, case decided on July 12, 2007 , LexisNexis #0807-037

In re James

Ruling
Notices of sale of tax liens containing legend required by Fair Debt Collection Practices Act did not violate stay.
Procedural posture

In separate cases, bankruptcy debtors moved for a finding that communications to the debtors from the former servicer of municipal tax liens against the debtors constituted attempts to collect prepetition debts from the debtors in violation of the automatic bankruptcy stay under 11 U.S.C. § 362(a)(5).

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opinion summary, case decided on July 09, 2007 , LexisNexis #0907-042

In re Carter

Ruling
Refusal of university to release debtor's daughter's diploma and academic records did not violate stay.
Procedural posture

The debtors filed a motion to compel against creditor, a university. Because the student accounts of the debtors'daughters were unpaid, the university enforced its policy regarding payment and refused to release the daughters'academic records and diploma. At issue was whether the university's refusal to release the documents was a violation of 11 U.S.C. § 362(a).

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opinion summary, case decided on May 24, 2007 , LexisNexis #0707-004

Flores v. DDJ Inc.

Ruling
Two year limitation on trustee's powers does not end the automatic stay.
Procedural posture

Plaintiff judgment creditors obtained a jury verdict for damages against defendant judgment debtors. After a judgment was entered, the creditors moved to add as judgment debtors various individuals and entities. The debtors filed petitions to commence chapter 7 bankruptcy. The court stayed the action pursuant to 11 U.S.C. § 362(a). One of the creditors moved for an order to calendar a hearing date certain on the motion to add judgment debtors.

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opinion summary, case decided on May 22, 2007 , LexisNexis #0707-021

Green Tree Serv. LLC v. Ivy (In re Ivy)

Ruling
Postpetition tax sale violated stay and was void.
Procedural posture

Plaintiff creditor filed a Fed. R. Bankr. P. 7056 motion for summary judgment on an adversary proceeding to set aside defendant county assessor's sale of defendant debtor's home to defendant buyer for delinquent taxes as violative of the automatic stay, pursuant to 11 U.S.C. § 362(a).

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opinion summary, case decided on May 18, 2007 , LexisNexis #0707-022

Live Nation Worldwide Inc. v. GTA Inc.

Ruling
Creditor could proceed against guarantor without first proceeding against debtor.
Procedural posture

A debtor executed a sublease whereby it agreed to sublease from plaintiff corporation. Concurrently with the sublease, defendant guarantor entered into a guaranty. The debtor filed a petition for relief under chapter 11. The corporation sued the guarantor to enforce the unconditional guaranty of payment. The corporation moved for summary judgment under Fed. R. Civ. P. 56.

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opinion summary, case decided on May 18, 2007 , LexisNexis #0607-107

In re Healthessentials Solutions Inc.

Ruling
Automatic stay applied to government lawsuit under False Claims Act.
Procedural posture

The United States (Government) filed a motion seeking entry of an order declaring that the automatic stay of 11 U.S.C. § 362(a)(1) did not apply to the Government's pursuit of a lawsuit under the False Claims Act, 31 U.S.C. § 3729-33.

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opinion summary, case decided on May 17, 2007 , LexisNexis #0607-124