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1st circuit

In re Montgomery

Ruling
Objection to confirmation was sustained since the "hanging paragraph"after section 1325(a)(9) prohibited bifurcation under section 506(a)(1) of the secured claim of a purchase-money moter vehicle creditor even where creditor failed to timely object.
Procedural posture

Respondent secured creditor objected to confirmation of petitioner debtors'proposed chapter 13 plan.

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opinion summary, case decided on May 17, 2006 , LexisNexis #0606-007

In re Grasso

Ruling
Trustee's motion to dismiss for debtor's failure to timely file tax returns was denied since untimely filing was due to attorney error and unharmed trustee did not have to seek dismissal.
Procedural posture

The chapter 7 trustee filed a motion to dismiss the case pursuant to 11 U.S.C. § 521(e)(2)(A) or for an order determining that the debtor had complied with 11 U.S.C. § 521(e)(2)(A) or was exempt from compliance under 11 U.S.C. § 521(e)(2)(B). The trustee filed the motion to dismiss because the debtor's tax returns were not submitted at least seven days prior to the 11 U.S.C. § 341 meeting, as required by 11 U.S.C. § 521(e)(2)(A).

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opinion summary, case decided on May 16, 2006 , LexisNexis #0606-072

Gonzalez-Ruiz v. Doral Fin. Corp. (In re Gonzalez-Ruiz)

Ruling
Court ruled that the bankruptcy court's order prohibiting debtors, who were serial filers and had attempted to refile to circumvent orders in their prior case, from making future filings.
Procedural posture

Appellant debtors challenged the Bankruptcy Court for the District of Puerto Rico's orders granting appellee creditor authority to proceed with a foreclosure sale of the debtors'residence, dismissing the debtors'fourth chapter 13 bankruptcy case, granting the creditor in rem relief from the automatic stay, barring the debtors from filing another bankruptcy petition, and denying the debtors'motion for reconsideration.

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Court :
Judge or Jurisdiction information not available
opinion summary, case decided on May 04, 2006 , LexisNexis #0506-114

In re Ring

Ruling
Court deemed that debtors'failure to provide tax returns to trustees was not grounds for dismissal but declined to issue bright line rule on tax return filings since the requests were not cases or controversies but rather anticipatory motions.
Procedural posture

In two cases filed after enactment of the Bankruptcy Abuse Prevention and Consumer Protection Act of 2005 ("BAPCPA"), consumer debtors sought orders determining that they had not violated the Bankruptcy Code's requirements for providing the chapter 7 and chapter 13 trustees with copies of prebankruptcy tax returns, as required by 11 U.S.C. § 521(e)(2)(A)(i), even though copies of the returns were provided to the trustees in either case.

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opinion summary, case decided on May 02, 2006 , LexisNexis #0606-042

In re Crane Rental Co.

Ruling
Late-filed proof of claim was allowed due to excusable neglect.
Procedural posture

Creditor provided health care, disability, pension and 401(K) plan benefits to heavy equipment operators working in the construction industry, including the employees of the debtor. The creditor filed a motion to amend its proof of claim, or in the alternative for leave to file a late claim.

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opinion summary, case decided on May 01, 2006 , LexisNexis #0506-140

Nickless v. Aaronson (In re Katz)

Ruling
Court abstained on ruling on trustee's efforts to obtain a winding up and accounting of a partnership in favor of a state court action.
Procedural posture

Plaintiff bankruptcy trustee brought an adversary proceeding against defendant partners in a partnership in which the debtor was also a partner, seeking a wind up of the partnership and a sale of partnership assets. The partners moved to dismiss the complaint for lack of subject matter jurisdiction.

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opinion summary, case decided on May 01, 2006 , LexisNexis #0606-067

Dufresne v. N.H. Higher Educ. Assistance Found. (In re Dufresne)

Ruling
Debtor's student loan debt was discharged due to undue hardship.
Procedural posture

By her complaint in an adversary proceeding, debtor sought a discharge of her outstanding student loans on an undue hardship basis under 11 U.S.C. § 523(a)(8). Defendant, the assignee of the loans, opposed their discharge. The matter was before the court for decision following trial.

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opinion summary, case decided on April 25, 2006 , LexisNexis #0506-128

Marrama v. Citizens Bank (In re Marrama)

Ruling
Denial of discharge was affirmed since fraudulent intent was found.
Procedural posture

Appellant debtor filed for chapter 7 bankruptcy protection. Appellee bank contended in its adversary action that the debtor should have been denied a discharge because of a recent transfer of assets to defraud creditors, pursuant to 11 U.S.C. § 727(a)(2)(A). The bankruptcy court entered summary judgment for the bank; the District Court for the District of Massachusetts affirmed. The debtor filed a further appeal.

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Court :
Judge or Jurisdiction information not available
opinion summary, case decided on April 20, 2006 , LexisNexis #0506-058

Access Cardiosystems Inc. v. Fincke (In re Access Cardiosystems Inc.)

Ruling
Former officer and director of debtor was denied a stay of judgment pending appeal of the judgment since the former officer did not establish that he had a substantial case on appeal.
Procedural posture

Plaintiffs, the debtor and various of the debtor's individual investors, sued defendant, a former director and officer of the debtor, seeking a declaratory judgment that the debtor owned certain intellectual property concerning an automated defibrillator system for which a patent application was pending. In a prior order, the court found in favor of plaintiffs. Defendant moved for stay pending appeal. He also moved to file papers under seal.

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opinion summary, case decided on April 17, 2006 , LexisNexis #0506-068

In re Kibbe

Ruling
Plan was denied confirmation since debtor incorrectly calculated projected disposable income based on Official Form B22C rather than Schedules I and J.
Procedural posture

The chapter 13 trustee filed a motion to dismiss the debtor's bankruptcy case. The issue presented was whether "projected disposable income," as used in 11 U.S.C. § 1325(b)(1)(B), was determined from Official Bankr. Form B22C or whether "projected disposable income" was determined by Schedules I and J, when the debtor's "current monthly income," as defined by 11 U.S.C. § 101(10A), was significantly lower than her actual current income.

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opinion summary, case decided on April 14, 2006 , LexisNexis #0606-115