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northern district of alabama

Iberiabank v. Yocum (In re Yocum)

Ruling
Discharge denied due to debtor's refusal to provide information on financial condition.
Procedural posture

Plaintiff bank moved for summary judgment on its complaint that defendant debtor was properly denied a discharge under 11 U.S.C.S. § 727. Debtor then filed a motion to voluntarily dismiss under 11 U.S.C.S. § 707.

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Consumer opinion summary, case decided on March 20, 2013 , LexisNexis #0413-060

Cadles of Grassy Meadows II LLC v. Guthrie (In re Guthrie)

Ruling
Judgment for increased litigation costs and attorneys' fees was nondischargeable due to collateral estoppel on issue of willful and malicious conduct.
Procedural posture

After recovering a state court judgment against defendant debtor that debtor was liable to plaintiff creditor for increased litigation costs and attorneys fees totaling $15,663, plaintiff creditor filed an adversary proceeding for a judgment that the obligation was nondischargeable per 11 U.S.C.S. § 523(a)(6) in debtor's chapter 7 case. At issue was whether Alabama's law of collateral estoppel applied to foreclose relitigation of that issue here.

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Consumer opinion summary, case decided on March 20, 2013 , LexisNexis #0413-053

Hall v. Burns (In re Burns)

Ruling
Failure to pay overtime was not a basis for nondischargeable debt.
Procedural posture

Creditor filed a complaint against chapter 7 debtor objecting to dischargeability of a debt under 11 U.S.C.S. § 523(a)(6). The complaint alleged that debtor failed to pay the creditor overtime for hours worked in excess of 40 hours per week in violation of 29 U.S.C.S. § 207(a) of the Fair Labor Standards Act (FLSA), and that the debtor retaliated against him for filing an FLSA complaint in violation of 29 U.S.C.S. § 215(a)(3).

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Consumer opinion summary, case decided on February 27, 2013 , LexisNexis #0313-088

API Holdings LLC v. Frost Cummings Tidwell Group LLC (In re Adams Produce Co. LLC)

Ruling
State law claims against debtor's predecessor's accounting firm remanded.
Procedural posture

An accounting firm filed a motion for remand pursuant to 28 U.S.C.S. § 1452(b), in the alternative for abstention, of claims of negligence, fraud, and state securities law violations brought against it by the corporate owner of the debtor.

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Commercial opinion summary, case decided on February 12, 2013 , LexisNexis #0313-032

Morgan v. Melissa Land Taylor Mgmt. Trust

Ruling
Court declined to abstain from trustee's proceeding for sale of property.
Procedural posture

Trustee filed this proceeding against purported claim or lienholders seeking a declaratory judgment that the estate was the owner of the Disputed Property because the Trustee was a bona fide purchaser for value pursuant to 11 U.S.C.S. § 544(a). As such, the Trustee also sought permission to sell the Disputed Property free and clear of all claims or liens. The proceeding was before the court on its Order to Show Cause.

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Consumer opinion summary, case decided on January 30, 2013 , LexisNexis #0213-101

In re Cooper

Ruling
Appeal of denial of motion for sanctions dismissed due to failure to comply with deadlines.
Procedural posture

After the bankruptcy court denied debtor's motion for sanctions against creditor for violation of the discharge injunction, the debtor appealed the order. The creditor filed a motion to dismiss the appeal.

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Consumer opinion summary, case decided on January 22, 2013 , LexisNexis #0313-034

In re Jefferson County

Ruling
Relief from stay for municipalities reliant on debtor county's hospital denied.
Procedural posture

Movants, various municipal entities reliant upon debtor county's hospital, requested a determination that the automatic stays of 11 U.S.C.S. §§ 362(a) and 922(a) did not apply to certain actions sought to be taken by the municipal parties. The dispute revolved around the provision of inpatient and emergency room medical care for indigent residents under the Alabama Health Care Responsibility Act (AHCRA), Ala. Code § 22-21-290 et seq.

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Commercial opinion summary, case decided on December 19, 2012 , LexisNexis #0113-024

In re Cunningham

Ruling
State court larceny judgment was nondischargeable.
Procedural posture

Creditor filed an adversary proceeding to determine whether a state court judgment against defendant, a chapter 13 debtor, was non-dischargeable under 11 U.S.C.S. § 523(a).

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Consumer opinion summary, case decided on November 14, 2012 , LexisNexis #1212-017

Toffel v. Gardner (In re Gardner)

Ruling
Conveyances made to avoid consequences of several lawsuits avoided as fraudulent.
Procedural posture

Chapter 7 trustee filed a complaint against a debtor's wife and son seeking to avoid and set aside certain real estate transfers as fraudulent conveyances pursuant to 11 U.S.C.S. § 544(b) and Ala. Code §§ 8-9A-4(a) and (c) and 8-9A-5(a) and (b). The trustee also sought a judgment against the wife for her half of the purchase price she received when she sold one of the properties transferred to a good faith purchaser.

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Consumer opinion summary, case decided on September 28, 2012 , LexisNexis #1212-023

Allen v. Scott (In re Scott)

Ruling
Debt based on unjust enrichment and breach of fiduciary duty to executrix of debtor's deceased relative's executrix was nondischargeable.
Procedural posture

The executrix of the parties' common relative filed a complaint asserting state law claims for conversion, undue influence, wantonness, felonious injury, and unjust enrichment. The executrix also sought nondischargeability and revocation of discharge of defendant, a chapter 7 debtor, who held a power of attorney from the decedent and had been appointed her guardian and conservator under Alabama law.

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Consumer opinion summary, case decided on September 27, 2012 , LexisNexis #1212-070