In re Manson

Pre 2005-Act: 
Pre 2005-Act
Debtor's motion to avoid lien was denied since lien was satisfied prior to filing of motion to avoid lien.
Procedural posture: 
The debtor's home had been exempt under 11 U.S.C. § 522 utilizing District of Columbia exemptions. She obtained a discharge that applied to a creditor's claim, but not on any lien that the creditor might have had. She discovered that the creditor had a judicial lien on her property when she refinanced her home. She reopened her chapter 7 case and moved to avoid the judicial lien pursuant to 11 U.S.C. § 522(f)(1)(A).
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