In re Brown

Foreclosure sale was held void since it violated automatic stay in place before case was dismissed for debtor's failure to meet section 109(h) requirements.
Procedural posture: 
The bankruptcy court issued a show cause order why a foreclosure sale conducted by the substitute trustee under the deed of trust should not be found void as a violation of the automatic stay, where the sale was conducted with knowledge of the bankruptcy filing, after the petition date and before dismissal, where the debtor was subsequently found to be ineligible for bankruptcy relief pursuant to 11 U.S.C. § 109(h).
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