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§ 362(b)(3)

Clarey, In re

Ruling
Court reasoned that filing a mechanic's lien to perfect a pre-existing lien does not violate the automatic stay. (Bankr. D.S.D.)
Issue(s)
Automatic Stay; Exceptions; Acts to Perfect, Maintain or Continue Perfection of an Interest in Property.

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Consumer opinion summary, case decided on November 18, 2024 , LexisNexis #0225-002

Puntas Assocs. LLC, In re--Punta Assocs., LLC v. Muñiz Ruiz

Ruling
Expiration of time to cure faults in mortgage deed and the withdrawal of the deedextinguished creditor's interest in the subject property. (Bankr. D.P.R.)
Issue(s)
Automatic Stay; Exceptions; Acts to Perfect, Maintain or Continue Perfection of an

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:
Judge or Jurisdiction information not available
Commercial opinion summary, case decided on October 29, 2021 , LexisNexis #1221-081

Walker In re

Ruling
Court ruled that mere possession of the vehicle of the debtor by the possessory lien holder did not automatically grant the latter the protection afforded by the law. (Bankr. N.D. Ill.)
Issue(s)
Automatic Stay; Exceptions; Acts to Perfect, Maintain or Continue Perfection of an Interest in Property.

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Consumer opinion summary, case decided on December 20, 2017 , LexisNexis #0118-094

Hernandez v. Banco Popular De Puerto Rico Popular Mortg. Inc. (In re Hernandez)

Ruling
Filed but unrecorded mortgage could be the basis for a secured claim.
Issue(s)
Whether a filed but unrecorded mortgage deed could be treated as a secured claim.

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Consumer opinion summary, case decided on March 18, 2016 , LexisNexis #0416-040

In re 800 Bourbon St. LLC

Ruling
Lien that was invalidated postpetition could be continued without violating the automatic stay and was not subject to avoidance.
Issue(s)
Should lien that was invalidated after the petition date be avoided?

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Commercial opinion summary, case decided on November 20, 2015 , LexisNexis #1215-038

Branch Banking & Trust Co. v. Construction Supervision Servs. (In re Construction Supervision Servs.)

Ruling
Liens that arose upon subcontractor's prepetition delivery of materials were interests in debtor's property, even though not perfected on petition date.
Issue(s)
Whether construction subcontractors entitled to a lien on funds under North Carolina law had an interest in property when the debtor contractor filed for bankruptcy, by which time the subcontractors had not yet served notice of, and thereby perfected, their liens.

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Court :
Judge or Jurisdiction information not available
Commercial opinion summary, case decided on May 22, 2014 , LexisNexis #0614-043

FirstBank P.R. v. Mujica (In re Mujica)

Ruling
Creditor failed to establish that it had a validly perfected lien on the petition date or that it was entitled to the postpetition recording exception.
Issue(s)
Whether a creditor had a validly perfected lien at the time of the filing of the debtor's bankruptcy petition and/or subject to be recorded post-petition under the exception provided by 11 U.S.C.S. § 362(b)(3).

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Consumer opinion summary, case decided on March 31, 2014 , LexisNexis #0714-039

Perez Mujica v. FirstBank P.R. (In re Perez Mujica)

Ruling
Relief from stay denied where creditor had not recorded mortgage and was unsecured.
Procedural posture

Plaintiff debtor, brought an adversary proceeding seeking a holding that defendant creditor did not have a perfected mortgage lien over its real property under P.R. Laws Ann. tit. 30, § 2260, and was unsecured. The creditor asserted it was entitled to relief from the automatic stay under 11 U.S.C.S. § 362(b)(3). The parties filed cross motions for summary judgment. The mortgage in issue was unrecorded at the time of the bankruptcy filing.

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Consumer opinion summary, case decided on September 08, 2011 , LexisNexis #1011-004

In re Rios

Ruling
Unrecorded mortgage liens were exempt from stay due to relation back mechanism of Puerto Rican law.
Procedural posture

In this chapter 11 case, the debtors filed an adversary proceeding against defendant creditor primarily with respect to the creditor's claim pertaining to mortgage liens and the creditor's contention that such liens were excepted from the automatic stay under 11 U.S.C.S. § 362(b)(3). The debtors filed a motion for summary judgment and the creditor filed a cross motion for summary judgment.

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Consumer opinion summary, case decided on April 07, 2010 , LexisNexis #0710-004

Tosado v. Banco Popular de P.R. (In re Rios)

Ruling
Unrecorded mortgage liens fell within perfection of property interest exception to stay.
Procedural posture

Debtors brought an adversary proceeding pursuant to 11 U.S.C.S. §§ 544(a), 547(b), 549. The proceeding was before the court upon debtors' motion for summary judgment. Creditor filed a cross-motion for summary judgment.

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Consumer opinion summary, case decided on November 20, 2009 , LexisNexis #0410-078