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§ 544(a)

Kuo, In re--Kuo v. Schulman

Ruling
Court held that Chapter 13 debtors have standing to exercise the trustee's avoidance powers when doing so would benefit the estate and creditors. (Bankr. N.D. Cal.)
Issue(s)
Trustee as Lien Creditor and as Successor to Certain Creditors and Purchasers; Rights and Powers; Trustee’s Avoidance Powers as Judicial Lien Creditor.

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Consumer opinion summary, case decided on February 24, 2025 , LexisNexis #0425-090

Simpkins, In re

Ruling
Trustee had a higher priority than the holder of an unperfected lien and could avoid it. (Bankr. D.N.J.)
Issue(s)
Trustee as Lien Creditor and as Successor to Certain Creditors and Purchasers; Rights and Powers; Trustee’s Avoidance Powers as Creditor with Unsatisfied Writ of Execution.

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Consumer opinion summary, case decided on November 18, 2024 , LexisNexis #0225-020

Fix, In re--Cafferty v. Fix

Ruling
Factual issues precluded summary judgment in avoidance proceeding involving unrecordedinterest in real estate. (Bankr. N.D. Ohio)
Issue(s)
Trustee as Lien Creditor and as Successor to Certain Creditors and Purchasers; Rights

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Consumer opinion summary, case decided on March 29, 2024 , LexisNexis #0624-013

Ho Wan Kwok, In re--Despins v. Lamp Cap. LLC

Ruling
Bankruptcy court had jurisdiction over claims brought by the trustee against several creditorsas a hypothetical creditor could bring these claims. (Bankr. D. Conn.)
Issue(s)
Trustee as Lien Creditor and as Successor to Certain Creditors and Purchasers; Rights and

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Consumer opinion summary, case decided on March 22, 2024 , LexisNexis #0524-065

Legacy Cares, Inc., In re--OVG Facilites, LLC v. Legacy Cares, Inc.

Ruling
Creditor could not obtain turnover of any of the personal property collateral as the securityinterests were unperfected and were defeated by the trustee’s hypothetical lien. (Bankr. D.Ariz.)
Issue(s)
Trustee as Lien Creditor and as Successor to Certain Creditors and Purchasers; Rights and

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Commercial opinion summary, case decided on November 21, 2023 , LexisNexis #0124-064

Legacy Cares, Inc., In re--OVG Facilites, LLC v. Legacy Cares, Inc.

Ruling
Creditor could not obtain turnover of any of the personal property collateral as the securityinterests were unperfected and were defeated by the trustee’s hypothetical lien. (Bankr. D.Ariz.)
Issue(s)
Trustee as Lien Creditor and as Successor to Certain Creditors and Purchasers; Rights and

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Commercial opinion summary, case decided on November 21, 2023 , LexisNexis #0124-064

Bunch, In re--Milligan v. Parton

Ruling
Trustee was entitled to avoid any right that the defendant might have had in property byvirtue of any executed, but unrecorded, deed of trust and recover the property for the estate.(Bankr. E.D. Tenn.)
Issue(s)
Trustee as Lien Creditor and as Successor to Certain Creditors and Purchasers; Rights and

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Consumer opinion summary, case decided on September 08, 2023 , LexisNexis #1123-041

Anstaett, In re--Williamson v. Southwind Bank

Ruling
Creditor claiming a security interest in a refinanced vehicle was not entitled to summaryjudgment on the trustee's avoidance claim as the trustee's rights as a lien creditor took priorityover an unperfected security interest. (Bankr. D. Kan.)
Issue(s)
Trustee as Lien Creditor and as Successor to Certain Creditors and Purchasers; Rights

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Consumer opinion summary, case decided on June 13, 2023 , LexisNexis #0823-034

Williams, In re--Hamilton v. Glob. Lending Servs., LLC

Ruling
Creditor's security interest was unperfected under state law and could be avoided. (Bankr. D. Kan.)
Issue(s)
Trustee as Lien Creditor and as Successor to Certain Creditors and Purchasers; Rights and Powers; Trustee’s Avoidance Powers as Judicial Lien Creditor.

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Consumer opinion summary, case decided on April 28, 2023 , LexisNexis #0623-091

Malone v. IOU Central, Inc.

Ruling
Defendant had no enforceable lien due to failure to dispute secured status when the claim wasdeemed unsecured or during the confirmation process. (Bankr. D. Or.)
Issue(s)
Trustee as Lien Creditor and as Successor to Certain Creditors and Purchasers; Rights and

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Consumer opinion summary, case decided on September 30, 2022 , LexisNexis #1222-015