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4th circuit

Ard, In re

Ruling
Debtors failed to prosecute their motion to impose the stay in third bankruptcy case filed within twelve months and proposed plan was not confirmable. (Bankr. D.S.C.)
Issue(s)
Automatic Stay; Duration; Cases Filed Within One Year of Dismissal of Two or More Prior Cases.

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Consumer opinion summary, case decided on May 23, 2025 , LexisNexis #0725-081

Williams Land Clearing, Grading, & Timber Logging, LLC, In re--Williams Land Clearing, Grading, & Timber Logging, LLC v. Apex Funding Source LLC

Ruling
Payment directly to creditor of receivable owed to debtor was avoidable as it allowed creditor to receive more than it would have in a Chapter 7 case. (Bankr. E.D.N.C.)
Issue(s)
Preferences.

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Commercial opinion summary, case decided on May 16, 2025 , LexisNexis #0725-065

Fall Creek One, LLC, In re

Ruling
Court valued creditor’s secured claim based on debtor’s income projections and intended use of property for short-term rentals. (Bankr. M.D.N.C.)
Issue(s)
Determination of Secured Status; Bifurcation of Claim; Valuation of Creditor’s Interest.

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Commercial opinion summary, case decided on May 09, 2025 , LexisNexis #0725-035

Wells, In re

Ruling
For an informal proof of claim to exist, the creditor must have taken some affirmative action in the bankruptcy case before the claims deadline to provide notice of the claim and intent to hold the estate liable. (Bankr. M.D.N.C.)
Issue(s)
Allowance of Claims or Interests; Disallowance; Proof of Claim not Timely Filed.

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Consumer opinion summary, case decided on May 07, 2025 , LexisNexis #0725-085

Ard, In re

Ruling
No stay violation found as debtors failed to prove willful conduct or resulting damages from home owners’ association’s actions. (Bankr. D.S.C.)
Issue(s)
Automatic Stay; Remedies for Violation.

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Consumer opinion summary, case decided on April 29, 2025 , LexisNexis #0725-031

Clouter Creek Reserve LLC, In re

Ruling
Court approved debtor’s post-petition financing allowing priming lien on property to enhance value and marketability, despite objections from existing lienholders. (Bankr. D.S.C.)
Issue(s)
Obtaining Credit; Secured by Lien with Priority over Existing Lien.

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Commercial opinion summary, case decided on April 18, 2025 , LexisNexis #0725-033

Serna, In re

Ruling
Dismissal or conversion to Chapter 13 denied as Chapter 7 debtors had insufficient ability to pay unsecured creditors in hypothetical Chapter 13 plan and lacked bad faith. (Bankr. D. Kan.)
Issue(s)
Dismissal of a Case or Conversion to a Case Under Chapter 11 or 13; Substantial Abuse.

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Consumer opinion summary, case decided on April 02, 2025 , LexisNexis #0725-045

Hurd, In re--Pearsall v. Hurd

Ruling
Complaint failed to identify any materially false written statement used by defendants to obtain loan from plaintiff before the debt was incurred. (Bankr. S.D. W. Va.)
Issue(s)
Exceptions to Discharge; Types of Debt Excepted; Fraud; False Financial Statement.

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Consumer opinion summary, case decided on March 26, 2025 , LexisNexis #0525-085

Rosen, In re--Rosen v. Tex. Guar. Student Loan Corp.

Ruling
Student loan debt was dischargeable where debtor met all three prongs of the Brunner test. (Bankr. W.D. Va.)
Issue(s)
Exceptions to Discharge; Types of Debt Excepted; Educational Loans.

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Consumer opinion summary, case decided on March 25, 2025 , LexisNexis #0525-086

Chanto, In re

Ruling
Extension of the automatic stay in debtor’s third case within two years denied due to failure to rebut the presumption of bad faith. (Bankr. D.S.C.)
Issue(s)
Automatic Stay; Duration; Cases Refiled Within One Year of Dismissal of One Prior Case.

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Consumer opinion summary, case decided on March 20, 2025 , LexisNexis #0525-080