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Bynum v. CitiMortgage Inc. (In re Bynum)

Bynum v. CitiMortgage Inc. (In re Bynum)

Ruling
Deed of trust did not create security interest in escrow funds but solely against residence, precluding modification.
Procedural posture

Plaintiff bankruptcy debtors brought an adversary proceeding against defendant creditor secured by a deed of trust against the debtors' principal residence, seeking a valuation of the residence for purposes of modifying the creditor's secured claim into secured and unsecured claims. The creditor moved to dismiss the complaint.

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Consumer opinion summary, case decided on July 20, 2012 , LexisNexis #0812-096