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§ 362(b)

In re Pollock

Ruling
State enforcement of wage, hour and overtime law was covered by the police powers exception to stay.
Procedural posture

The debtor challenged an order issued by the New York Department of Labor (DOL) requiring the debtor to comply with wage, hour, and overtime law, asserting that the order violated the automatic stay provision of 11 U.S.C.S. § 362. The issue was whether the police and regulatory powers exception to the automatic stay provision under 11 U.S.C.S. § 362(b)(4) was applicable to the DOL's order.

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Consumer opinion summary, case decided on February 24, 2009 , LexisNexis #0609-039

Jahn v. United States (In re WinPar Hospitality Chattanooga LLC)

Ruling
Government forfeiture proceeding predicated on postpetition criminal activity did not violate stay.
Procedural posture

Plaintiff trustee filed an action against defendant government, alleging that the government violated the automatic stay of 11 U.S.C.S. § 362 by seeking the forfeiture of estate property. The trustee filed a motion for partial summary judgment, and the government filed a cross- motion for summary judgment and a motion to dismiss.

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Commercial opinion summary, case decided on February 06, 2009 , LexisNexis #0309-109

Davison v. Kanipe

Ruling
Postpetition negotiation of prepetition check did not violate stay where creditor returned funds upon notice of filing.
Procedural posture

Appellant debtor challenged an order of the United States Bankruptcy Court for the Eastern District of Tennessee that denied her motion to declare a violation of the automatic stay under 11 U.S.C.S. § 362, to impose sanctions against appellee creditor, a check cashing service that negotiated, postpetition, a pre-petition check she had written pursuant to the Deferred Presentment Services Act, authorized by Tenn. Code Ann. § 45-17-101 et seq.

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Consumer opinion summary, case decided on February 05, 2009 , LexisNexis #0309-040

Garcia-Lawson v. Garland

Ruling
Stay applied to marriage dissolution action only to extent property of the estate would be distributed.
Procedural posture

Appellant chapter 13 debtor moved for a temporary restraining order and sanctions against appellee husband's attorneys, alleging that 11 U.S.C.S. § 362 imposed an automatic stay on the civil proceedings for dissolution of marriage. The bankruptcy court denied the Fed. R. Bankr. P. 8003 motion, the husband's motion for relief from the automatic stay, and the attorneys' motion to quash subpoenas. The debtor moved for leave to appeal the orders.

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Consumer opinion summary, case decided on December 03, 2008 , LexisNexis #0109-043

In re Mystic Tank Lines Corp.

Ruling
Default judgment for environmental clean-up after debtor caused a gasoline leak was within police powers exception to stay.
Procedural posture

Appellant debtor, a gasoline shipper, challenged a judgment of the United States District Court for the District of New Jersey, affirming the bankruptcy court's allowance of a claim by appellee the State of New York based on damages for the clean-up of soil and groundwater contaminated with petroleum products caused by a leak at a gas station that was traced to a delivery of gasoline by the debtor.

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Court :
Judge or Jurisdiction information not available
Commercial opinion summary, case decided on October 16, 2008 , LexisNexis #1108-060

Bartel v. Walsh (In re Bartel)

Ruling
There are no exceptions to criminal prosecution exception from stay.
Procedural posture

Plaintiff, the chapter 7 debtor, brought adversary claims seeking damages and injunctive relief against defendants, a former district attorney (D.A.) and a state police officer, alleging they violated the automatic stay by instituting criminal proceedings against him and seizing his financial records pursuant to a search warrant, depriving him of the protection of the automatic stay. The D.A. and the officer moved for summary judgment.

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Consumer opinion summary, case decided on October 16, 2008 , LexisNexis #1108-059

Vasquez v. Georgia Dept of Human Res. Office of Child Support Servs.

Ruling
Bankruptcy court erred in assuming wage granishment by state was related to a valid domestic support obligation.
Procedural posture

Appellant debtor sought review of a decision of a bankruptcy court, which denied the debtor's motion to stop the garnishment of the debtor's wages by appellee the Georgia Department of Human Resources, Office of Child Support Services (State).

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Consumer opinion summary, case decided on September 30, 2008 , LexisNexis #1008-111

United States v. Henry

Ruling
Criminal contempt proceeding for debtor's deletion of computer files that were subject to subpeona was not subject to stay.
Procedural posture

Intervening plaintiffs filed a motion for sanctions and the issuance of an order to show cause why movant should not have been held in contempt of court.

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Consumer opinion summary, case decided on July 01, 2008 , LexisNexis #0708-112

In re Keuler

Ruling
Tax liens filed against debtor's property during pendency of prior owner's bankruptcy were void.
Procedural posture

Debtor objected to a secured proof of claim for real estate property taxes filed by creditor, a county.

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Consumer opinion summary, case decided on May 14, 2008 , LexisNexis #1008-094

In re Winer

Ruling
Eviction action not stayed where judgment of possession was obtained prior to petition date.
Procedural posture

Debtor filed a petition for relief under chapter 7 of the Bankruptcy Code, and two weeks later, the debtor's landlord filed a motion seeking an order confirming the absence of the automatic stay, pursuant to 11 U.S.C.S. § 362(b)(22), in the alternative, granting the landlord relief from the automatic stay, pursuant to 11 U.S.C.S. § 362(d). The debtor opposed the motion.

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Consumer opinion summary, case decided on May 13, 2008 , LexisNexis #0608-111