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§ 362(c)

In re Matthews

Ruling
Case dismissed with one year filing bar due to lack of good faith.
Procedural posture

Chapter 7 debtor filed a motion to extend the automatic stay pursuant to 11 U.S.C.S. § 362(c)(3), the primary creditor filed a motion to dismiss debtor's case for abuse pursuant to 11 U.S.C.S. § 707(b).

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Consumer opinion summary, case decided on April 03, 2013 , LexisNexis #0413-112

In re Larijani

Ruling
Debtors' fourth case dismissed due to failure to obtain required credit counseling.
Procedural posture

Putative chapter 13 debtor filed a motion to vacate a prior court order dismissing his instant case, and requesting an extension of time within which to obtain credit counseling services, on the grounds that a foreclosure was scheduled for the day after he filed his bankruptcy petition. When debtor had failed to appear at a hearing on the counseling issue, his case was dismissed.

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Consumer opinion summary, case decided on April 03, 2013 , LexisNexis #0413-111

In re Dyer

Ruling
Bankruptcy court abused discretion in dismissing case and ordering disgorgement of fees based on alleged termination of stay.
Procedural posture

Chapter 13 debtors appealed from an order of the United States Bankruptcy Court for the Southern District of Ohio, that denied confirmation of the debtors' plan, dismissed the debtors' case, and ordered disgorgement of the debtors' counsel's fees.

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Court :
Judge or Jurisdiction information not available
Consumer opinion summary, case decided on March 14, 2013 , LexisNexis #0413-004

In re Hart

Ruling
Court declined to impose stay in debtor's third case in one year due to presumption of bad faith.
Procedural posture

Debtor filed a petition under chapter 7 of the Bankruptcy Code in January 2013, after two chapter 13 bankruptcy cases he filed in 2012 were dismissed, and he asked the court to impose the automatic stay on all creditors. A chapter 7 trustee who was appointed to administer the debtor's case and the United States, on behalf of the Internal Revenue Service ("IRS"), opposed the debtor's motion.

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Consumer opinion summary, case decided on February 26, 2013 , LexisNexis #0313-083

In re Hart

Ruling
Extension of stay denied due to presumption of bad faith.
Procedural posture

Debtor filed a second petition under chapter 13. Creditor, the Internal Revenue Service (IRS) sought to reduce to judgment certain outstanding federal tax liabilities assessed against him, and to foreclose certain federal tax liens on a parcel of real property. The debtor filed a motion to extend the automatic stay beyond the 30th day after the second petition was filed, under 11 U.S.C.S. § 362(c)(3). The IRS objected to that relief.

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Consumer opinion summary, case decided on November 23, 2012 , LexisNexis #0113-108

In re Payton

Ruling
Extension of stay granted in case filed within 180 days of prior voluntary dismissal, which was not requested following filing of motion for relief from stay.
Procedural posture

A chapter 13 debtor filed a motion for an extension of the automatic stay under 11 U.S.C.S. § 362(c)(3). The Chapter 13 trustee moved to dismiss, asserting that the debtor was ineligible for bankruptcy relief under 11 U.S.C.S. § 109(g)(2).

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Consumer opinion summary, case decided on November 05, 2012 , LexisNexis #1112-110

Santander Consumer USA Inc. v. Houlik (In re Houlik)

Ruling
Award of sanctions for creditor's repossession of vehicle one year after confirmation and two months after case was closed without discharge reversed and vacated.
Procedural posture

Creditor challenged an order of the U.S. Bankruptcy Court for the District of Kansas awarding actual damages of $474 and punitive damages of $25,000 to appellees, the individual chapter 11 debtors, as a sanction for its repossession of their vehicle.

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Court :
Judge or Jurisdiction information not available
Consumer opinion summary, case decided on October 29, 2012 , LexisNexis #1112-080

Timmons v. Rose Acceptance Inc. (In re Timmons)

Ruling
Debtor granted temporary relief from order allowing foreclosure to proceed due to improved circumstances.
Procedural posture

Plaintiff chapter 13 debtor filed an adversary proceeding against defendant creditor and sought an order restraining the creditor from selling his home in a foreclosure sale. The court held a hearing on the debtor's motion.

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Consumer opinion summary, case decided on September 20, 2012 , LexisNexis #1012-115

Eastern Savings Bank v. Toor (In re Toor)

Ruling
Ruling that debtor's third case in one year was filed in good faith affirmed.
Procedural posture

Creditor challenged a decision of the United States Bankruptcy Court for the District of Connecticut, which granted debtor's motion to impose the automatic stay pursuant to 11 U.S.C.S. § 362(c)(4)(C).

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Consumer opinion summary, case decided on June 22, 2012 , LexisNexis #0712-077

In re Scott-Hood

Ruling
Order terminating stay as to debtor's real property reversed on reconsideration.
Procedural posture

Debtor filed a motion to reconsider or vacate the court's order confirming termination of the automatic stay in her chapter 13 case. Debtor's motion sought a determination that the stay remained in full force and effect with respect to the real property at issue under the terms of 11 U.S.C.S. § 362(c)(3)(A), because such property was property of the estate, not property of the debtor.

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Consumer opinion summary, case decided on June 18, 2012 , LexisNexis #0712-076