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§ 362(h)

In re Arnell

Ruling
Creditor credit union violated stay by exercising unauthorized setoff against debtor's account.
Procedural posture

Chapter 7 debtor filed a motion for sanctions against creditor, a credit union, pursuant to 11 U.S.C. § 362(h).

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opinion summary, case decided on December 26, 2006 , LexisNexis #0307-092

In re Conley

Ruling
Comfort order not available to confirm termination of stay due to debtor's failure to state intention to reaffirm debt or redeem collateral.
Procedural posture

A creditor filed a motion for the entry of a comfort order confirming the termination of the automatic stay, pursuant to 11 U.S.C. § 362(j), as to the debtors'automobile.

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opinion summary, case decided on November 22, 2006 , LexisNexis #0107-044

In re McFall

Ruling
Auto repossession did not violate stay which had expired due to debtor's failure to indicate intention to reaffirm debt or redeem collateral.
Procedural posture

Debtor, an individual, moved for an order requiring claimant, a secured creditor, to show cause why it should not be held in contempt for allegedly violating the automatic stay. At issue was whether debtor's statement that he intended to retain certain collateral and to make regular monthly payments thereon satisfied the requirements of 11 U.S.C. § 362(h)(1).

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opinion summary, case decided on November 22, 2006 , LexisNexis #0107-043

Hanson v. LTD Commodities LLC (In re Hanson)

Ruling
Default judgment for willful violation of stay denied where facts supported violation of discharge injunction.
Procedural posture

Plaintiff debtors filed an adversary complaint against defendants, a creditor and its attorneys, seeking damages for a willful violation of the automatic stay under 11 U.S.C. § 362(h). Defendants failed to answer, and the debtors sought the entry of a default judgment, an award of attorney fees, and punitive damages.

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opinion summary, case decided on November 21, 2006 , LexisNexis #0107-056

In re Steinhaus

Ruling
Stay terminated 30 days after filing where debtor did not elect to either redeem or reaffirm debt secured by automobile.
Procedural posture

A creditor filed a motion to confirm termination of an automatic stay, compel surrender of a vehicle, and authorize foreclosure upon the vehicle in the debtors'chapter 7 case. The court held a hearing on the motion.

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opinion summary, case decided on September 01, 2006 , LexisNexis #1006-042

Bentley v. Nissan Motor Acceptance Corp. (In re Bentley)

Ruling
Creditor's knowing repossession of debtor's vehicle was a willfull violation of stay.
Procedural posture

Plaintiff bankruptcy debtor brought an adversary proceeding against defendant creditor for violating the automatic stay by postpetition repossession of the debtor's vehicle. In the debtor's main case, the debtor also objected to the creditor's amended proof of claim, and the creditor moved for relief from the stay. The bankruptcy court conducted a trial addressing all of these matters.

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opinion summary, case decided on August 10, 2006 , LexisNexis #0906-017

Rehabiltated Inner City Hous LLC v. Mayor of Baltimore City ( In re Lesick)

Ruling
Limited liability company had standing to pursue automatic stay violation action, but court dismissed action seeking damages for stay violation under section 362(h).
Procedural posture

Defendants, a mayor, a city council, tax sale purchasers, and assignees, filed a motion to dismiss plaintiff limited liability company's ("LLC") action. The LLC sought to have certain tax sales declared void due to violation of the automatic stay in a chapter 7 case and sought damages under former 11 U.S.C. § 362(h) (current version at 11 U.S.C. § 362(k)(1)).

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opinion summary, case decided on July 19, 2006 , LexisNexis #0806-083

In re Atamian

Ruling
Debtor was granted motion for actual and punitive damages for creditor's violation of stay.
Procedural posture

Debtor filed a motion pursuant to 11 U.S.C. § 362(h) for sanctions, damages, and punitive damages against creditor and the creditor's insurer, as subrogee. The creditor opposed the motion and also filed a request for clarification of the court's previous order that granted the creditor limited relief from the automatic stay to permit the creditor to continue to pursue claims against the debtor.

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opinion summary, case decided on June 15, 2006 , LexisNexis #0706-052

In re Boring

Ruling
Motion to confirm absence of automatic stay was granted since debtor's statement of intention failed to state whether debtor was reaffirming, redeeming, or surrendering collateral securing debt.
Procedural posture

A creditor filed a motion to confirm the absence of the automatic stay after the debtor failed to affirmatively state on her statement of intention whether she was reaffirming, redeeming, or surrendering the collateral that secured her debt.

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opinion summary, case decided on May 30, 2006 , LexisNexis #0806-005

In re Bennet

Ruling
Reaffirmation of debt secured by real property denied as not in best interests of debtor since payments were current and ride-through limits applied only to personal property.
Procedural posture

The debtors and a creditor sought approval of a reaffirmation agreement regarding real property.

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opinion summary, case decided on May 26, 2006 , LexisNexis #1006-041