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National Commer. Recovery Inc. v. McClanahan (In re McClanahan)

Ruling
Debtor's failure to pay dealer in transaction subject to the Perishable Agricultural Commodities Act was not a fiduciary defalcation that would render the resulting debt nondischargeable.
Issue(s)
Where transactions between debtor and creditor's predecessor (produce dealer) were subject to the provisions of the statutory trust created by PACA, 7 U.S.C.S. §§ 499a-499t, whether debtor's failure to pay the dealer was a defalcation while acting in a fiduciary capacity for purposes of nondischargeability under 11 U.S.C.S. § 523(a)(4).

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Consumer opinion summary, case decided on October 01, 2014 , LexisNexis #1014-125

In re Dekoning

Ruling
Junior lien could not be treated as unsecured based on fair market value of property.
Issue(s)
Whether a bank's junior lien was wholly unsecured and could be treated as a general unsecured claim in debtors' chapter 13 plan.

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Consumer opinion summary, case decided on August 27, 2014 , LexisNexis #0914-132

Black v. HSBC Bank USA (In re Black)

Ruling
Creditors did not violate stay where eviction was protected by in rem order from another bankruptcy court.
Issue(s)
Did "in rem" order for relief from the automatic stay by another bankruptcy court in another debtor's case prior to commencement of debtor's bankruptcy case protect creditor's efforts to proceed with an eviction from the application of the automatic stay?

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Consumer opinion summary, case decided on July 25, 2014 , LexisNexis #0814-080

McCarthy v. Giron

Ruling
Co-owners were liable for debts of corporation on basis of fraud.
Issue(s)
Whether the co-owners of a debtor corporation were liable in a bankruptcy proceeding for debts of the corporation under 11 U.S.C.S. § 544(b).

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Consumer opinion summary, case decided on June 06, 2014 , LexisNexis #0714-014

In re Kutumian

Ruling
Debtor awarded attorneys' fees and costs incurred prior to termination of stay violation.
Issue(s)
What was the appropriate amount of damages, specifically attorney's fees and costs, that the debtor can recover as a result of the knowing violation of stay by creditor in pursuing construction defects action?

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Consumer opinion summary, case decided on May 15, 2014 , LexisNexis #0614-079

In re Perez

Ruling
Debtors' third chapter 11 case ordered converted or dismissed with filing bar.
Issue(s)
Should debtors' third chapter 11 case filed within 18 months be dismissed with a 180-day filing bar?

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Consumer opinion summary, case decided on May 14, 2014 , LexisNexis #0614-128

In re South Lakes Dairy Farm

Ruling
Fees of attorneys for committee of unsecured creditors approved as reasonable given waiver of fees for defending final application and limitation on fees in prior fee applications.
Issue(s)
Should final fee application of attorneys for unsecured creditors' committee be allowed?

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Commercial opinion summary, case decided on January 22, 2014 , LexisNexis #0214-109

In re Maxwell

Ruling
Plan modification denied as not proposed in good faith due to failure to share benefits of increased income and loan modification with creditors.
Issue(s)
Was trustee's "good faith" objection to modified plan appropriate, on grounds that the modification did not reflect increase in debtors' income or amount saved on loan modification, where distribution to creditors was not decreased.

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Consumer opinion summary, case decided on November 08, 2013 , LexisNexis #1213-066

Landis v. Orozco (In re Orozco)

Ruling
Debtor serial filer's fourth case dismissed with prejudice due to bad faith and abuse of system.
Issue(s)
Should serial filer's fourth case be dismissed for bad faith.

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Consumer opinion summary, case decided on October 21, 2013 , LexisNexis #1113-128

In re Cortez

Ruling
Bankruptcy petition preparer fined and ordered to disgorge fees due to failure to sign petition, file Official Form 19 and for nondisclosures.
Procedural posture

The U.S. Trustee's Motion For Fines And Disgorgement To Debtor Under 11 U.S.C.S. § 110 came on for hearing. The U.S. Trustee's pleadings were unopposed.

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Consumer opinion summary, case decided on July 10, 2013 , LexisNexis #0813-072