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§ 109(e)

In re Cummings

Ruling
State court issuance of writ of attachment was preclusive as to liquidated nature of claim so that debtor exceeded chapter 13 debt limits.
Issue(s)
Was claim for which state court issued a writ of attachment liquidated so as to cause debtor to exceed chapter 13 debt limits and require dismissal or conversion?

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Consumer opinion summary, case decided on November 20, 2015 , LexisNexis #1215-036

In re Stebbins

Ruling
Case dismissed as debtor's guarantee of mortgage was noncontingent and caused debtor to exceed debt limit for chapter 13.
Issue(s)
Did mortgage debt cause debtor to exceed chapter 13 debt limits or was it a contingent and unliquidated debt to which the limit did not apply?

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Consumer opinion summary, case decided on February 24, 2015 , LexisNexis #0315-071

Sergio v. Garcia (In re Garcia)

Ruling
Chapter 13 case dismissed due to total unsecured debt in excess of jurisdictional limits.
Issue(s)
Whether debtor has too much unsecured debt to be in a Chapter 13 case, turning on whether debtor's wholly unsecured junior mortgages count as unsecured debts under § 109(e)?

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Consumer opinion summary, case decided on October 03, 2014 , LexisNexis #1014-108

In re Prawer

Ruling
Debtor not eligible under chapter 13 due to debt in excess of limits.
Issue(s)
Did chapter 13 debtor have noncontingent, liquidated, undisputed debts in excess of limits?

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Consumer opinion summary, case decided on September 22, 2014 , LexisNexis #1014-073

In re Sugg

Ruling
Claim for breach of fiduciary duty was not liquidated and did not disqualify debtors from eligibility under chapter 13.
Issue(s)
Did debtor's combined unsecured debts exceed the upper limit allowed for chapter 13 eligibility?

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Consumer opinion summary, case decided on July 22, 2014 , LexisNexis #0814-072

General Lending Corp. v. Cancio

Ruling
Creditor's untimely objection to debtor's eligibility properly barred by bankruptcy court.
Issue(s)
Did the laches bar imposed by the bankruptcy court to creditor's eligibility challenge under 11 U.S.C.S. § 109(e) eliminate a statutory condition of confirmation?

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Consumer opinion summary, case decided on January 29, 2014 , LexisNexis #0714-001

In re Yuen

Ruling
Debtor was ineligible due to debt in excess of chapter 13 limits.
Issue(s)
Was debtor with more than $367,000 in scheduled unsecured debt eligible under chapter 13.

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Consumer opinion summary, case decided on October 09, 2013 , LexisNexis #1013-106

In re Walls

Ruling
Issue of whether IRS secured nonpriority claim was discharged in prior case has to be resolved in an adversary proceeding as it went to eligibility.
Issue(s)
Whether a chapter 13 debtor's claim that an unsecured nonpriority claim the Internal Revenue Service ("IRS") filed against his bankruptcy estate could be resolved as a contested matter or had to be resolved in an adversary proceeding, and if an adversary proceeding was required, whether that proceeding had to be filed in the debtor's earlier bankruptcy case after that case were reopened or could be filed in the debtor's open chapter 13 case.

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Consumer opinion summary, case decided on July 09, 2013 , LexisNexis #0813-001

In re Jones

Ruling
Case ordered converted or dismissed due to unsecured debt in excess of chapter 13 limits.
Procedural posture

Debtor filed a chapter 13 bankruptcy case. The chapter 13 Trustee filed a petition to dismiss the case alleging that the debtor was over the jurisdictional limits of 11 U.S.C.S. § 109(e) and was therefore ineligible for chapter 13 relief.

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Consumer opinion summary, case decided on May 28, 2013 , LexisNexis #0713-001

In re Miller

Ruling
Case ordered dismissed or converted due to unsecured debt in excess of chapter 13 limits.
Procedural posture

A bankruptcy trustee filed a motion to dismiss the chapter 13 bankruptcy case filed by the debtors.

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Consumer opinion summary, case decided on May 21, 2013 , LexisNexis #0613-107