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District of minnesota

In re Fields

Ruling
Chapter 13 debtor not engaged in business could incur secured debt and obtain credit via planmodification. (Bankr. D. Minn.)
Issue(s)
Does the Bankruptcy Code2 require a debtor in a chapter 13 case — who is not "engaged in business" — to obtain court approval when seeking [*3] to obtain post-petition credit and to incur debt to purchase a vehicle?

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Consumer opinion summary, case decided on June 01, 2016 , LexisNexis #0816-085

Kelley v. Opportunity Fin. LLC (In re Petters Co.)

Ruling
Trustee could recover of at least the ostensible interest-component that debtors paid to certain defendants and other investors pursuant to alleged Ponzi scheme.
Issue(s)
To what extent could trustee avoid certain transactions that were part of a Ponzi scheme under a state uniform fraudulent transfer act?

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Consumer opinion summary, case decided on May 31, 2016 , LexisNexis #0616-123

In re Fields

Ruling
Court authorization not required for debtor not engaged in business to purchase automobile.
Issue(s)
Should the bankruptcy court grant individual chapter 13 debtors authorization to incur debt and secure credit to purchase a motor vehicle?

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Consumer opinion summary, case decided on May 27, 2016 , LexisNexis #0616-103

Kelley v. Opportunity Fin. LLC (In re Petters Co.)

Ruling
Substantive consolidation did not affect trustee's avoidance rights.
Issue(s)
Whether in application of the state law of fraudulent transfer, after the substantive-consolidation of the estates of multiple debtors, the trustee may use the standing of a prepetition creditor of one of those debtor-entities to satisfy the predicate-creditor requirement for the avoidance of a pre-petition transfer made by another of the debtor-entities, where the proposed predicate creditor itself had no pre- petition claim against the transferor-debtor.

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Commercial opinion summary, case decided on May 19, 2016 , LexisNexis #0616-124

In re Walz

Ruling
Interest in house acquired les than 180 days after petition date was property of the estate and qualified as a homestead in which debtor could clam an exemption.
Issue(s)
Was debtor entitled to a homestead exemption on property she resided in but did not own on the petition date?

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Consumer opinion summary, case decided on March 15, 2016 , LexisNexis #0416-055

Stoebner v. Larson (In re Larson)

Ruling
Discharge denied due to significant omissions of income and assets.
Issue(s)
Were significant omissions of income and assets from schedules grounds for a denial of debtor's discharge?

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Consumer opinion summary, case decided on March 02, 2016 , LexisNexis #0316-130

County of Dakota v. Milan (In re Milan)

Ruling
"Pay to stay" costs assessed against debtor inmate were not excepted from discharge.
Issue(s)
Whether costs charged to inmates under Minnesota's "pay to stay" program were excepted from a debtor's bankruptcy discharge.

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Consumer opinion summary, case decided on March 01, 2016 , LexisNexis #0316-122

Kelley v. Associated Bank (In re Petters Co.)

Ruling
Ponzi scheme presumption could not serve as basis for holding that transfers to bank to cover overdrafts were fraudulent.
Issue(s)
Were transfers to debtor's bank to cover overdrafts avoidable as fraudulent?

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Consumer opinion summary, case decided on February 29, 2016 , LexisNexis #0416-022

In re Yotis

Ruling
Creditor's postpetition mortgage fees and expenses allowed to the extent necessary to cure debtor's default.
Issue(s)
Should fees and other charges claimed by mortgage creditor in its notice of postpetition fees, expenses, and charges be allowed?

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Consumer opinion summary, case decided on February 04, 2016 , LexisNexis #0316-030

Stoebner v. Opportunity Fin. LLC (In re Polaroid Corp.)

Ruling
Trustee could not avoid transfers by companies owned by debtor's owner but that were not currently in bankruptcy.
Issue(s)
Could transfers by nondebtor companies owned by debtor's owner be avoided?

ABI Membership is required to access the full summary of Stoebner v. Opportunity Fin. LLC (In re Polaroid Corp.) Please sign in if you are already an ABI member, or otherwise you may Become an ABI Member

Commercial opinion summary, case decided on January 14, 2016 , LexisNexis #0216-085