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southern district of ohio

Frances E. Bain Estate v. Hammen (In re Hammen)

Ruling
Claim for trespass was not excepted from discharge absent evidence of willful or malicious conduct.
Procedural posture

Plaintiff, the estate of a deceased property owner, filed a complaint against defendant chapter 7 debtors, alleging that the debtors encroached on the owner's land when they constructed a pond on their adjacent property. It sought damages and an exception from discharge due to fraud or willful injury under 11 U.S.C.S. § 523(a)(2)(A) and § 523(a)(6).

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Consumer opinion summary, case decided on January 23, 2009 , LexisNexis #0309-011

Butler v. Ormet Corp.

Ruling
Time-barred wrongful discharge claim properly disallowed by bankruptcy court.
Procedural posture

Appellant, a claimant in a chapter 11 case, challenged a denial, by the Bankruptcy Court for the Southern District of Ohio, of a Fed. R. Civ. P. 59(e) motion for reconsideration of its denial of an earlier motion under 11 U.S.C.S. § 502(j) and Fed. R. Bankr. P. 3008 to set aside the order disallowing his claim against appellee debtors. At issue was whether the bankruptcy court had abused its discretion in so ruling.

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Commercial opinion summary, case decided on January 13, 2009 , LexisNexis #0309-031

Weisle Corp. v. Leist (In re Leist)

Ruling
Debtor real estate broker's purchase of property instead of making offer on behalf of clients resulted in nondischargeable economic injury.
Procedural posture

Plaintiffs, a judgment creditor and its principal, and defendant chapter 7 debtor filed cross-motions for summary judgment in plaintiffs' action, which sought to have the judgment debt declared nondischargeable pursuant to 11 U.S.C.S. § 523(a)(4) and § 523(a)(6).

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Consumer opinion summary, case decided on December 16, 2008 , LexisNexis #0209-046

In re Cincom iOutsource Inc.

Ruling
Proof of claim failed after creditor was added to amended schedule was deemed timely.
Procedural posture

Debtor corporation filed a petition under chapter 7 of the Bankruptcy Code, and a trustee was appointed to represent the bankruptcy estate. Movant creditor filed a proof of claim after the deadline established by the court, and moved for an order deeming its proof of claim as timely. The trustee and another creditor opposed the creditor's motion.

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Commercial opinion summary, case decided on November 20, 2008 , LexisNexis #0109-021

In re Peppers

Ruling
First mortgage on debtor's home was not subject to modification.
Procedural posture

The debtor filed an objection to a proof of claim filed by the creditor which held a first mortgage on the debtor's home. The objection contested the creditor's arrearage claim. The debtor believed that a portion of the claim should be paid as an unsecured claim pursuant to 11 U.S.C.S. § 506(a).

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Consumer opinion summary, case decided on November 18, 2008 , LexisNexis #1208-113

In re Cinecom iOutsource Inc.

Ruling
Action by unaffiliated non-debtor entities against debtor were subject to stay.
Procedural posture

The chapter 7 trustee filed a motion to enforce the automatic stay under 11 U.S.C.S. § 362(a) in three separate actions filed in federal district courts by unaffiliated, non-debtor entities.

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Commercial opinion summary, case decided on October 31, 2008 , LexisNexis #0109-042

In re Street

Ruling
Exemption in debtor's postpetition property division payments from former spouse allowed over trustee's objection.
Procedural posture

A bankruptcy debtor claimed exemptions in postpetition payments from her former spouse as part of a property division in divorce proceedings in which the debtor relinquished her interests in the spouse's retirement plan and a marital residence in exchange for the payments. The bankruptcy trustee objected to the exemptions.

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Consumer opinion summary, case decided on September 30, 2008 , LexisNexis #1008-076

In re Hlavin

Ruling
Home loans secured by mortgages were consumer, not commercial, debts.
Procedural posture

The Trustee sought dismissal of the debtors' bankruptcy case for abuse under 11 U.S.C.S. § 707(b)(1). The debtors moved for partial summary judgment.

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Consumer opinion summary, case decided on September 30, 2008 , LexisNexis #1008-071

Argent Mortg. Co. LLC v. Drown (In re Bunn)

Ruling
Mortgage with sufficient property identification to create constructive notice under state law was not avoidable.
Procedural posture

Defendant mortgage creditor appealed from an order of the bankruptcy court for the Southern District of Ohio, that held that the plaintiff, the chapter 7 trustee, could avoid the debtor's mortgage under 11 U.S.C.S. § 544(a)(3), because the face of the mortgage contained a street address and a parcel number, but did not contain a legal description of the debtor's residential property.

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Consumer opinion summary, case decided on September 30, 2008 , LexisNexis #1208-097

Clippard v. Ragle (In re Ragle)

Ruling
Bankruptcy court properly allowed debtor to deduct ownership expense for vehicle owned free and clear.
Procedural posture

Appellant United States Trustee filed a motion for a rehearing a decision of the court, which dismissed, for lack of jurisdiction, his appeal of the bankruptcy court's order denying his motion to dismiss appellee debtors'chapter 7 bankruptcy case under 11 U.S.C.S. § 707(b)(1).

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Consumer opinion summary, case decided on September 29, 2008 , LexisNexis #1008-084