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§ 524(a)(2)

Konop v. Hawaiian Airlines Inc. (In re Hawaiian Airlines Inc.)

Ruling
Sanctions against pilot for violating confirmation order in employer's case upheld.
Procedural posture

The Bankruptcy Court for the District of Hawaii held on November 24, 2008, that appellant pilot had violated the Confirmation Order, and ordered dismissal of the claims that he had commenced against appellee debtor airline. The bankruptcy court also imposed sanctions against him. He appealed the bankruptcy court's Order. He also requested judicial notice of two letters relating to arbitration proceedings.

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Commercial opinion summary, case decided on April 08, 2009 , LexisNexis #0509-100

Jones v. Walter Mortg. Co. (In re Jones)

Ruling
Secured creditor's purchase of required hazard insurance that debtor failed to provide did not violate discharge injunction.
Procedural posture

A debtor filed for relief under chapter 13 of the Bankruptcy Code, and a plan was confirmed. As part of the plan, the debtor paid her secured obligations to defendant creditors. After confirmation, the creditors sought a payment of $4,524 for hazard insurance on the encumbered property. The debtor filed an adversary proceeding challenging the creditors' conduct and sought to file an amended complaint and to certify a class.

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Consumer opinion summary, case decided on January 12, 2009 , LexisNexis #0309-100

Jefferson v. Midwest Urological Group Ltd. (In re Jefferson)

Ruling
Violation of discharge injunction did not merit punitive damages absent evidence of financial loss.
Procedural posture

After receiving a discharge, plaintiff chapter 7 debtor sued defendant medical services provider, alleging that the provider violated the automatic stay and the discharge injunction by continuing to attempt to collect a debt, and seeking compensatory damages, attorney fees, and punitive damages. The provider failed to appear or file a responsive pleading. The debtor moved for a default judgment.

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Consumer opinion summary, case decided on November 07, 2008 , LexisNexis #1208-083

Winslow v. Salem Five Mortg. Co. LLC (In re Winslow)

Ruling
Creditor violated discharge injunction by publishing inaccurate credit report.
Procedural posture

Plaintiff debtor sought damages from defendant creditor for violation of the discharge injunction under 11 U.S.C.S. § 524(a)(2). She alleged that the creditor, a mortgage company, published inaccurate credit reports and issued improper default notices.

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Consumer opinion summary, case decided on July 30, 2008 , LexisNexis #1208-066

Paul v. Iglehart (In re Paul)

Ruling
Continuation of litigation in which debtors were nominal defendants including pursuit of discovery did not violate discharge injunction.
Procedural posture

This case concerned the protective scope of the discharge injunction. Plaintiff debtors brought an adversary proceeding against defendant, a state court plaintiff, alleging violation of the discharge injunction of 11 U.S.C.S. § 524(a)(2). The District Court for the District of Colorado held that the state court plaintiff violated the discharge injunction. The state court plaintiff appealed.

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Court :
Judge or Jurisdiction information not available
Consumer opinion summary, case decided on July 28, 2008 , LexisNexis #0808-099

Espinosa v. United States Aid Funds Inc.

Ruling
Finding that student loan creditor violated discharge injunction reversed and remanded as contrary to terms of debtor's plan.
Procedural posture

Plaintiff debtor petitioned a bankruptcy court for an order holding defendant creditor in contempt for violating a discharge injunction, under 11 U.S.C.S. § 524(a)(2). The creditor cross-moved for relief from the bankruptcy court's order confirming a chapter 13 bankruptcy plan. The bankruptcy court held that the creditor violated the discharge injunction. The United States District Court for the District of Arizona reversed. The debtor appealed.

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Court :
Judge or Jurisdiction information not available
Consumer opinion summary, case decided on June 24, 2008 , LexisNexis #0708-102

Gunter v. Kevin OBrien & Assocs. Co. LPA (In re Gunter)

Ruling
Bankruptcy court declined to sanction creditor for obtaining state court judgment in unwitting violation of discharge and vacting the judgment upon notice.
Procedural posture

Chapter 7 debtor sought to sanction defendant, the law firm for a creditor, for violations of the discharge injunction set forth in 11 U.S.C.S. § 524(a)(2).

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Consumer opinion summary, case decided on June 17, 2008 , LexisNexis #0708-103

In re Jones

Ruling
Collection agency and its attorney, but not creditor who hired them, were liable for violation of discharge injunction.
Procedural posture

Chapter 7 debtor and his co-debtor spouse filed a motion for contempt sanctions for a violation of the discharge injunction of 11 U.S.C.S. § 524(a)(2) against a creditor, a collection agency, and the agency's attorney.

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Consumer opinion summary, case decided on April 10, 2008 , LexisNexis #0608-063

In re Miller

Ruling
Creditor sanctioned for pursuing state court action against debtor in willful violation of discharge injunction.
Procedural posture

Chapter 7 debtors, a husband and wife, filed a motion pursuant to 11 U.S.C.S. § 524(a)(2) for contempt sanctions against a creditor and its counsel for violating the discharge injunction.

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Consumer opinion summary, case decided on March 26, 2008 , LexisNexis #0508-065

Saint Torrance v. Cincinnati Gas & Elec. Co. (In re Saint Torrance)

Ruling
Creditor's efforts to collect postpetition debt did not violate discharge injunction.
Procedural posture

Appellant debtor had filed for relief under chapter 7. The debtor sought review of a decision of the Bankruptcy Court for the Southern District of Ohio, which dismissed the debtor's complaint for damages and injunctive relief against defendant utility company.

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Court :
Judge or Jurisdiction information not available
Consumer opinion summary, case decided on September 26, 2007 , LexisNexis #1007-100