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District of ohio

In re Murray

Ruling
Although stay was not in effect in debtors'third chapter 13 filing, any action by creditor involving property of the estate was to be brought in bankruptcy court.
Procedural posture

A creditor filed a motion for an order confirming the inapplicability of the automatic stay, pursuant to 11 U.S.C. § 362(c)(3)(C)(ii). The debtors responded that a creditor action involving the debtors'property was to occur exclusively in bankruptcy court during the pendency of the chapter 13 case.

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opinion summary, case decided on September 11, 2006 , LexisNexis #1006-040

Ohio Crime Victims Reparations Fund v. Harwell (In re Harwell)

Ruling
Debt owed to victim of debtor's assault with knife was not excepted from discharge as guilty plea was not dispositive of willful and malicious injury and evidence was consistent with self-defense.
Procedural posture

Plaintiff, a state crime victims reparations fund brought an adversary proceeding against defendant bankruptcy debtor, alleging that a debt to the fund for amounts the fund paid to the victim of the debtor's assault was not dischargeable under 11 U.S.C. § 523(a)(6), based on the willful and malicious nature of the assault. The bankruptcy court conducted a trial.

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opinion summary, case decided on August 25, 2006 , LexisNexis #1006-092

In re Myers

Ruling
Competency was not necessary to qualify as debtor and court could appoint next friend in order to aid in administration of case pursuant to equitable powers.
Procedural posture

Chapter 13 debtor wife filed a motion to become the next friend of debtor husband pursuant to Fed. R. Bankr. P. 1004.1.

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opinion summary, case decided on August 24, 2006 , LexisNexis #1006-071

Monnie v. Field (In re Bross)

Ruling
Mortgage not executed in compliance with state law could be avoided.
Procedural posture

Appellant closing agent challenged a judgment of a U.S. bankruptcy court, which granted the motion of summary judgment filed by appellee bankruptcy trustee, allowing the trustee to avoid, pursuant to 11 U.S.C. § 544(a)(3), a mortgage in favor of defendant mortgagee on the ground that the mortgage was defective under Ohio Rev. Code Ann. § 5301.01 because it was not signed.

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opinion summary, case decided on August 16, 2006 , LexisNexis #0906-007

In re Laury

Ruling
Waiver of filing fee granted where debtor was below 150% poverty standard.
Procedural posture

A debtor filed an application to waive the chapter 7 bankruptcy filing fee pursuant to 28 U.S.C. § 1930(f).

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opinion summary, case decided on August 15, 2006 , LexisNexis #1106-017

Board of Trustees of the Ohio CarpentersPension Fund v. Bucci

Ruling
ERISA employer contribution debt was dischargeable in absence of trustee status that could give rise to defalcation.
Procedural posture

Plaintiff, a multiemployer ERISA plan that was maintained pursuant to a collective bargaining agreement and governed by various trust agreements, sought review of a decision of the bankruptcy court, which found that defendant debtor's ERISA employer contribution debt was dischargeable under 11 U.S.C. § 523(a)(4). The debtor was the alter ego of his business, which had entered into chapter 7 bankruptcy.

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opinion summary, case decided on August 14, 2006 , LexisNexis #0906-086

In re Rose

Ruling
Lien creditor's loss on stripped car allowed as administrative expense claim.
Procedural posture

Chapter 13 secured creditor filed a motion for an allowance of an administrative claim under 11 U.S.C. § 503 in an amount representing the value of creditor's secured claim less payments already received under debtor's plan.

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opinion summary, case decided on August 11, 2006 , LexisNexis #0906-018

In re Ermi

Ruling
Creditor was not entitled to comfort order where debtors failed to timely assume vehicle lease but had not previously filed for bankruptcy.
Procedural posture

Bankruptcy debtors identified their interest in a vehicle lease on their schedules and subsequently amended their schedules to indicate their intention to assume the unexpired lease. A creditor with a security interest in the vehicle moved for a comfort order pursuant to 11 U.S.C. § 362(j) confirming that the automatic stay terminated with regard to the vehicle based on the lack of a timely indication of intent and/or assumption of the lease.

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opinion summary, case decided on August 03, 2006 , LexisNexis #1106-009

In re Caravona

Ruling
Criminal prosecution of bad check charges did not violate stay.
Procedural posture

Chapter 7 debtor filed a motion pursuant to 11 U.S.C. § 350(b) to reopen his case to ask that creditor and a county district attorney be held in contempt for violating the automatic stay, 11 U.S.C. § 362, discharge injunction, 11 U.S.C. § 524, by taking steps to collect a bad check debt from him through criminal prosecution.

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opinion summary, case decided on July 28, 2006 , LexisNexis #1006-009

In re Payne

Ruling
Creditor's objection to confirmation was overruled since section 1325(a) hanging paragraph applied.
Procedural posture

Creditor objected to the confirmation of chapter 13 debtors'plan.

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opinion summary, case decided on July 10, 2006 , LexisNexis #0806-113