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northern district of alabama

In re Roberts

Ruling
Debtor's failure to make car payments due to incarceration was not due to bad faith and was not grounds for denial of confirmation.
Procedural posture

The issue of confirmation of debtor's proposed chapter 13 plan and creditor auto dealer's objection to confirmation on good faith grounds, pursuant to 11 U.S.C. § 1325(a)(3) and (7) was before the court. Debtor also objected to the classification of creditor's $5,136.16 claim.

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opinion summary, case decided on March 29, 2007 , LexisNexis #0507-013

Butler v. United States Bankruptcy Court

Ruling
Dismissal due to debtors'failure to pay filing fee upheld.
Procedural posture

Plaintiff debtors appealed a decision of the bankruptcy court, which dismissed the debtors'chapter 7 bankruptcy petition for failure to timely pay their filing fee under 11 U.S.C. § 707(a)(2) and denied their motion to reinstate the case.

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opinion summary, case decided on March 26, 2007 , LexisNexis #0507-009

Elite Equip. Inc. v. Cornutt

Ruling
Bankruptcy court erred in requiring creditor to pierce corporate veil in dischargeability proceeding alleging fraud by individual debtor.
Procedural posture

Before the court was an appeal from an order by the Bankruptcy Court for the Northern District of Alabama entering judgment in favor of appellee debtor and against appellant on its complaint in an adversary proceeding.

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opinion summary, case decided on March 19, 2007 , LexisNexis #0507-092

In re Arnold

Ruling
Trustee permitted to pay late filed secured claim provided there were no objections.
Procedural posture

Creditor, a homeowners'association, filed a motion to allow a late-filed proof of claim. Although no response opposing the motion was filed, nor did any party appear in opposition at the hearing, the court nevertheless had a concern whether a legal basis existed for granting the requested relief, and the court took the motion under advisement.

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opinion summary, case decided on February 26, 2007 , LexisNexis #0407-124

In re Nwonwu

Ruling
Claims bar date could not be extended but late claim of homeowners' association could be paid absent objection.
Procedural posture

Debtor filed a voluntary petition for adjustment of her debts under chapter 13. After a modified repayment plan was confirmed, creditor homeowners association filed a motion to allow a late-filed secured claim.

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opinion summary, case decided on February 23, 2007 , LexisNexis #0407-054

Chi Chiu v. Barnard (In re Barnard)

Ruling
Stay continued in debtor's fourth case conditioned upon payment of postpetition rent and timely payment of future rents.
Procedural posture

Respondent debtor sought bankruptcy relief under chapter 13. Movant creditor sought relief from the automatic stay order to prosecute an unlawful detainer action for possession of real property that was rented by the debtor.

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opinion summary, case decided on February 08, 2007 , LexisNexis #0407-001

Talley v. Alabama Dept of Public Safety

Ruling
Suspension of driver's license for debtor's ongoing failure to pay fines was excepted from stay as a continuation of prior criminal proceeding.
Procedural posture

Appellant, a chapter 13 debtor, sought review of a decision of the bankruptcy court, which dismissed the debtor's adversary proceeding brought against appellees, the Alabama Department of Public Safety and a state official, alleging that the suspension of the driver's license of the debtor violated the automatic stay imposed by 11 U.S.C. § 362.

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opinion summary, case decided on January 30, 2007 , LexisNexis #0307-021

In re Moon

Ruling
Creditor subject to "hanging paragraph"had no basis to assert unsecured claim after surrender of vehicle.
Procedural posture

The debtor moved to confirm her chapter 13 plan. Creditor filed an objection to confirmation on the grounds that it was not adequately protected by the debtor's proposed plan pursuant to which the debtor proposed to surrender the creditor's collateral, a vehicle, in full satisfaction of the creditor's claim.

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opinion summary, case decided on January 26, 2007 , LexisNexis #0407-139

In re Miller

Ruling
Above median income debtors'disposable income properly calculated using IRS standards and Form B22C.
Procedural posture

Chapter 13 trustee in bankruptcy filed objection to the confirmation of debtors'proposed chapter 13 plan, on the ground that the debtors did not commit all of their projected disposable income to make payments to unsecured creditors as required by 11 U.S.C. § 1325(b)(1)(B). At issue was the proper application of the disposable income test to above median income debtors under the Bankruptcy Abuse Prevention and Consumer Protection Act of 2005.

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opinion summary, case decided on January 18, 2007 , LexisNexis #0307-083

In re Hackney

Ruling
Debtor could not reopen chapter 11 case that had been dismissed rather than closed.
Procedural posture

Debtor filed a motion to reopen his chapter 11 case pursuant to 11 U.S.C. § 350(b). Creditor, debtor's ex-wife, filed an objection.

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opinion summary, case decided on January 12, 2007 , LexisNexis #0307-088