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Moshannon Valley Citizens v. Rosewood Real Estate Inc. (In re Moshannon Valley Citizens Inc.)

Ruling
Action by debtor-in-possession against prospective purchaser for breach of contract was a core proceeding.
Procedural posture

Debtor-in-possession, the operator of a hospital, filed a Complaint seeking injunctive relief and damages for breach of contract against prospective purchasers of the hospital. The complaint alleged that the prospective purchasers were in breach of the purchase agreement and related security agreements.

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Commercial opinion summary, case decided on February 25, 2009 , LexisNexis #0509-056

Dehart v. Lopatka (In re Lopatka)

Ruling
Above median debtor with negative disposable income could propose plan with term of less than five years.
Procedural posture

Chapter 13 trustee filed an objection to confirmation of the debtor's plan, asserting that the above-median debtor's plan with a negative projected monthly disposable income could not be confirmed over the objection if the plan did not provide full payment of all allowed unsecured claims and was for less than five years. The court considered whether the plan duration could be set at less than five years.

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Consumer opinion summary, case decided on February 17, 2009 , LexisNexis #0409-091

Estes Express Lines v. Paone (In re Paone)

Ruling
Stay lifted to allow determination of debtor's liability in state tort action.
Procedural posture

Company filed a motion to lift the automatic stay, pursuant to 11 U.S.C.S. § 362, in order to join debtor in a state court tort action and allow a factfinder to apportion liability between the company and debtor, pursuant to 42 Pa. Cons. Stat. § 7102(b).

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Consumer opinion summary, case decided on February 12, 2009 , LexisNexis #0409-112

Keuler v. Monroe County Tax Claim Bureau

Ruling
Ad valorem taxes assessed during pre-BAPCPA case were not exempt from stay.
Procedural posture

Appellant tax claim bureau appealed a decision by a bankruptcy court which denied the bureau's objections to a chapter 13 debtor's petition to sell real property that was part of her bankruptcy estate.

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Consumer opinion summary, case decided on January 26, 2009 , LexisNexis #0309-030

McGuire v. United States

Ruling
Sovereign immunity barred bankruptcy court from considering debtor's taking claim against the Bureau of Indian Affairs under the Tucker Act.
Procedural posture

Plaintiff claimant, a bankrupt farmer, sought review of a judgment from the District Court for the District of Arizona which rejected the bankruptcy court's recommendation of a damage award to plaintiff on his inverse condemnation claim against defendant United States. The district court agreed with the bankruptcy court that the Government's actions could qualify as a regulatory taking but held that plaintiff's claim was not ripe for review.

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Court :
Judge or Jurisdiction information not available
Consumer opinion summary, case decided on December 24, 2008 , LexisNexis #0109-105

Atrium View LLC v. Eastern Savings Bank (In re Atrium View LLC)

Ruling
Prepayment premium claimed by first lienholder against proceeds of auction disallowed as unreasonable.
Procedural posture

Objectants, a Chapter 7 debtor and a third lienholder, asserted that a prepayment premium asserted by respondent first lienholder against the proceeds of an auction sale of certain real estate was unreasonable and should be disallowed pursuant to 11 U.S.C.S. § 506(b).

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Commercial opinion summary, case decided on December 24, 2008 , LexisNexis #0209-008

DeHart v. Baden (In re Baden)

Ruling
Confirmation denied due to debtor's exclusion of unemployment compensation from current monthly income calculation.
Procedural posture

The chapter 13 trustee filed an objection to the confirmation of the debtors' chapter 13 plan. The trustee asserted that the debtors' improperly excluded unemployment compensation that the husband received under the Social Security Act in the calculation of current monthly income (CMI). The trustee contended that this treatment of unemployment compensation violated 11 U.S.C.S. § 1322(a)(1).

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Consumer opinion summary, case decided on October 30, 2008 , LexisNexis #0109-023

In re McMaster

Ruling
Attorneys'fees for chapter 11 trustee and attorney for chapter 11 trustee allowed as justified and reasonable.
Procedural posture

A debtor objected to an application for fees and expenses incurred by an attorney for the chapter 11 trustee and for compensation for the chapter 11 trustee.

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Consumer opinion summary, case decided on October 17, 2008 , LexisNexis #0109-030

In re Bird

Ruling
Nunc pro tunc approval of attorneys'fees from period before filing of application for approval denied.
Procedural posture

An attorney for the chapter 7 trustee requested reimbursement for fees and expenses incurred prior to the date of the filing of an application to approve the attorney's employment.

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Consumer opinion summary, case decided on October 17, 2008 , LexisNexis #0209-024

Stauder v. eCast Settlement Corp. (In re Stauder)

Ruling
Credit card proofs of claim supported only by "account summaries" disallowed.
Procedural posture

The debtors objected to three proofs of claim filed by the same creditor. The substance of each objection was that the creditor failed to attach sufficient documentation to the claim form to allow that claim to be accorded "prima facie"validity.

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Consumer opinion summary, case decided on October 16, 2008 , LexisNexis #0109-028