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In re Tarnowski

Ruling
Reaffirmation agreement could not be approved due to debtor's lack of fixed salary and failure to exhaust less expensive options.
Procedural posture

The debtors filed for relief under chapter 7 of the Bankruptcy Code. The debtors sought to reaffirm a debt to a creditor for the financing of the debtors' vehicle.

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Consumer opinion summary, case decided on February 11, 2009 , LexisNexis #0309-118

In re Byers

Ruling
Approval of reaffirmation agreement denied due to failure to rebut presumption of undue hardship.
Procedural posture

A debtor filed for relief under chapter 7 of the Bankruptcy Code. The debtor sought approval of a reaffirmation agreement between the debtor and a creditor, pursuant to 11 U.S.C.S. § 524(c). The debtor was represented by counsel.

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Consumer opinion summary, case decided on February 11, 2009 , LexisNexis #0309-119

Jackson v. Bryant (In re Bryant)

Ruling
Marital debts were nondischargeable where debtor cited only state of economy as cause of possible reduced future earnings.
Procedural posture

Plaintiff, defendant debtor's former spouse, filed an adversary proceeding seeking a determination that marital debts were nondischargeable pursuant to 11 U.S.C.S. § 523(a)(5) or (a)(15).

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Consumer opinion summary, case decided on February 03, 2009 , LexisNexis #0309-063

Pearce v. E.L.W. Corp. (In re Pearce)

Ruling
Creditor subcontractor's contacting police to commence criminal charges against debtor violated stay.
Procedural posture

Plaintiff debtor filed an adversary proceeding against defendant creditor for sanctions for violation of the automatic stay under 11 U.S.C.S. § 362 and the permanent injunction under 11 U.S.C.S. § 524(a).

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Consumer opinion summary, case decided on January 27, 2009 , LexisNexis #0309-006

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

Farmers Savings Bank v. Kucera (In re Kucera)

Ruling
Dischargeability complaint filed on next business day after expiration of 60-day deadline was timely.
Procedural posture

Chapter 7 debtors filed a motion to dismiss plaintiff creditor's complaint, which sought to determine the dischargeability of debt owed it by the debtors under 11 U.S.C.S. § 523(a)(2), on the grounds that the complaint was untimely filed pursuant to Fed. R. Bankr. P. 4007(c).

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Consumer opinion summary, case decided on January 16, 2009 , LexisNexis #0209-076

In re Wait

Ruling
Mortgage is not an executory contract and need not be assumed or rejected by trustee.
Procedural posture

The chapter 7 trustee objected to the debtor's claim of a homestead exemption under Iowa Code §§ 499A.18, 561.16, 561.19, and 561.20. The debtor moved for abandonment of property, asserting that the mortgage encumbering the property was an executory contract under 11 U.S.C.S. § 365(d)(1), because the trustee did not assume or reject it, it was deemed rejected.

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Consumer opinion summary, case decided on December 30, 2008 , LexisNexis #0209-006

In re Sickels

Ruling
Objection to recission of reaffirmation agreement on grounds of mutual mistake overruled.
Procedural posture

When debtors, a married couple who had filed a chapter 7, attempted to rescind a reaffirmation agreement that they had executed with a credit union that held an unrecorded mortgage on their residence, on the ground of mutual mistake, the credit union objected. At issue, inter alia, was whether the statutory period for rescission under 11 U.S.C.S. § 524(c) had expired.

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Consumer opinion summary, case decided on November 20, 2008 , LexisNexis #0109-081

Chase Bank USA v. Swanson (In re Swanson)

Ruling
Credit card debt incurred for "luxury goods" was nondischargeable.
Procedural posture

Creditor, a credit card issuer, filed an adversary complaint alleging that certain of debtor's obligations on a credit card issued by creditor were nondischargeable pursuant to 11 U.S.C.S. § 523(a)(2)(A) and (C) as luxury goods or on the basis that debtor did not intend to pay the amounts involved. Debtor denied that the debt was nondischargeable. The matter was tried to the court.

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Consumer opinion summary, case decided on November 13, 2008 , LexisNexis #0409-048

In re Smith

Ruling
Real estate commissions earned prior to petition date were property of the estate and subject to turnover.
Procedural posture

A debtor filed for relief under chapter 7 of the Bankruptcy Code. A trustee filed a motion for turnover of real estate commissions, pursuant to 11 U.S.C.S. §§ 541 and 542, claiming that the debtor earned the commissions prior to filing for bankruptcy and that the commissions were property of the estate.

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Consumer opinion summary, case decided on October 31, 2008 , LexisNexis #1208-096