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Bankruptcy Appellate Panel

Rios Vargas, In re--Rios Vargas v. Planet Home Lending, LLC

Ruling
Amended proof of claim allowed because misidentification of creditor was a curable defect and did not show bad faith. (B.A.P. 1st Cir.)
Issue(s)
Reconsideration of Claims.

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Commercial opinion summary, case decided on August 28, 2025 , LexisNexis #1125-025

Sterling, In re--Sterling v. Southlake Nautilus Health & Racquet Club, Inc.

Ruling
Fees awarded as compensatory damages for violation of discharge injunction that caused injury to debtor. (7th Cir.)
Issue(s)
Effect of Discharge; Avoidance And Injunctive Relief; Injunction Against Actions to Recover a Debt as Personal Liability of Debtor.

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Consumer opinion summary, case decided on June 20, 2025 , LexisNexis #0825-089

Muszynski v. Millennium Funding, Inc.

Ruling
Bankruptcy court did not abuse its discretion in finding that the debtor failed to describe exigent circumstances meriting a waiver of the credit counseling requirement. (B.A.P. 1st Cir.)
Issue(s)
Who May Be a Debtor; Mandatory Credit Counseling.

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Consumer opinion summary, case decided on March 07, 2025 , LexisNexis #0525-026

Las Martas, Inc. v. Condado 5, LLC

Ruling
Bankruptcy court erred in dismissing Chapter 12 case by comparing financial conditions across debtor’s multiple filings instead of focusing solely on pospetition conditions in the current case. (B.A.P. 1st Cir.)
Issue(s)
Conversion or Dismissal; Dismissal for Cause on Request of Party in Interest; Continuing Loss or Diminution of Estate.

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Commercial opinion summary, case decided on March 05, 2025 , LexisNexis #0525-042

Promise Healthcare Grp., LLC v. Michaelson

Ruling
Claim for which the statute of limitations would have expired during the bankruptcy case was enforceable based on enforceability on the petition date. (3d Cir.)
Issue(s)
Allowance of Claims or Interests.

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Commercial opinion summary, case decided on March 03, 2025 , LexisNexis #0425-083

Roberts, In re--Roberts v. Sender

Ruling
Bankruptcy court did not abuse its discretion by failing to adjudicate objections to the creditors' claim before approving the settlement. (B.A.P. 10th Cir.)
Issue(s)
Compromise and Arbitration.

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Consumer opinion summary, case decided on February 26, 2025 , LexisNexis #0425-100

Levine, In re--Fluharty v. Phila. Indem. Co.

Ruling
Trustee for company that was a debtor in another case lacked standing to sue D&O insurer directly while the underlying action against debtor CEO was ongoing as the company was not a first-party insured. (4th Cir.)
Issue(s)
Property of the Estate.

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Consumer opinion summary, case decided on February 26, 2025 , LexisNexis #0425-089

Carrigan, In re

Ruling
Debtor's amended plan was patently unconfirmable as it failed to provide for full payment of priority tax claims. (B.A.P. 1st Cir.)
Issue(s)
Automatic Stay; Duration.

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Consumer opinion summary, case decided on February 18, 2025 , LexisNexis #0425-081

Human Hous. Henrietta Hyatt, LLC, In re--Clearview Eastern Fund, LLC v. Woodward

Ruling
Appellants were limited on appeal to challenging whether the purchasers were good faith purchasers as they failed to obtain a stay of the sale orders. (B.A.P. 6th Cir.)
Issue(s)
Use, Sale, or Lease of Property; Protection for Good Faith Purchasers.

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Commercial opinion summary, case decided on January 21, 2025 , LexisNexis #0325-082

Frontline Med. Servs. LLC, In re--Busch Law Firm, LLC v. Frontline Med. Servs. LLC I

Ruling
Bankruptcy court erred in confirming plan by applying the incorrect feasibility test for a nonconsensual Subchapter V plan. (B.A.P. 10th Cir.)
Issue(s)
Confirmation of Plan.

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Commercial opinion summary, case decided on December 26, 2024 , LexisNexis #0325-016