Skip to main content

§ 506(d)

In re Young

Ruling
Homeowners' association's fully unsecured lien could be stripped off.
Procedural posture

The chapter 13 debtor filed a motion to value her residence and to determine the status of a lien held by a homeowner's association (HOA). She contended that the lien should be deemed unsecured pursuant to 11 U.S.C.S. § 506.

ABI Membership is required to access the full summary of In re Young Please sign in if you are already an ABI member, or otherwise you may Become an ABI Member

Consumer opinion summary, case decided on November 07, 2012 , LexisNexis #1112-116

Flores v. TCF Bank (In re Flores)

Ruling
Wholly unsecured second lien could be stripped off upon successful completion of plan.
Procedural posture

Plaintiff chapter 13 debtors filed a complaint against defendant bank pursuant to 11 U.S.C.S. § 506(a) and (d) and Fed. R. Bankr. P. 3012 and 7001(2) seeking to determine the value of the bank's interest in the debtors' residential real estate and to determine the status of the bank's claims.

ABI Membership is required to access the full summary of Flores v. TCF Bank (In re Flores) Please sign in if you are already an ABI member, or otherwise you may Become an ABI Member

Consumer opinion summary, case decided on October 01, 2012 , LexisNexis #1012-121

Shelton v. CitiMortgage Inc. (In re Shelton)

Ruling
Avoidance proceeding properly dismissed where sole grounds for avoidance of lien was untimeliness of proof of claim.
Procedural posture

Appellant debtors sought review of a decision from the United States Bankruptcy Court for the Eastern District of Arkansas, granting appellee creditor's motion to dismiss the debtors' adversary proceeding seeking the avoidance of the creditor's lien on the debtors' residence.

ABI Membership is required to access the full summary of Shelton v. CitiMortgage Inc. (In re Shelton) Please sign in if you are already an ABI member, or otherwise you may Become an ABI Member

Court :
Judge or Jurisdiction information not available
Consumer opinion summary, case decided on September 24, 2012 , LexisNexis #1012-078

Christo v. Wells Fargo Bank (In re Christo)

Ruling
Chapter 7 debtors could not strip off allowed unsecured junior lien.
Procedural posture

Defendant creditor filed a motion to dismiss the adversary proceeding brought by plaintiff discharged chapter 7 debtors, which ostensibly sought a determination that the second mortgage held by the creditor against their residence should be avoided.

ABI Membership is required to access the full summary of Christo v. Wells Fargo Bank (In re Christo) Please sign in if you are already an ABI member, or otherwise you may Become an ABI Member

Consumer opinion summary, case decided on September 04, 2012 , LexisNexis #1012-079

Woolsey v. Woolsey (In re Woolsey)

Ruling
Second mortgage that was secured under state law could not be voided in chapter 13 case even though unsupported by value in collateral.
Procedural posture

Appellee creditor objected to appellant debtors' chapter 13 plan. The bankruptcy court rejected the plan, and the United States District Court for the District of Utah affirmed. The debtors appealed.

ABI Membership is required to access the full summary of Woolsey v. Woolsey (In re Woolsey) Please sign in if you are already an ABI member, or otherwise you may Become an ABI Member

Court :
Judge or Jurisdiction information not available
Consumer opinion summary, case decided on September 04, 2012 , LexisNexis #1012-011

In re Parks

Ruling
Rents that were subject of an absolute assignment were not property of the estate but ordered to be collected directly by creditor.
Procedural posture

Movant, a chapter 13 debtor who had defaulted on a note held by a creditor and secured by a mortgage and an absolute assignment of rents, sought confirmation of a plan that provided for monthly plan payments against a "cramdown" amount. The creditor objected to the plan. Issues included the amount that was actually due on the note and the effect, if any, of 11 U.S.C.S. § 506(d) on the rights of the parties.

ABI Membership is required to access the full summary of In re Parks Please sign in if you are already an ABI member, or otherwise you may Become an ABI Member

Consumer opinion summary, case decided on August 16, 2012 , LexisNexis #0912-076

Hill v. South Central Bank (In re Hill)

Ruling
Wholly unsecured third lien on debtor's property could be avoided.
Procedural posture

Debtors brought an adversary proceeding against creditor seeking a determination that the creditor's third position mortgage lien against the debtors' real property was void under 11 U.S.C.S. § 506(d).

ABI Membership is required to access the full summary of Hill v. South Central Bank (In re Hill) Please sign in if you are already an ABI member, or otherwise you may Become an ABI Member

Consumer opinion summary, case decided on May 31, 2012 , LexisNexis #0712-014

Vazquez v. Bank of Am.

Ruling
Lien stripped off due to lack of value and equity in subject property.
Procedural posture

Debtor brought an adversary proceeding against bank which held a second mortgage lien against the debtor's real property, seeking a determination of the validity of the bank's lien and alleging that the lien was void. The bank did not respond to the complaint.

ABI Membership is required to access the full summary of Vazquez v. Bank of Am. Please sign in if you are already an ABI member, or otherwise you may Become an ABI Member

Consumer opinion summary, case decided on November 18, 2011 , LexisNexis #1211-080

Smoot v. Wachovia Mortg. (In re Smoot)

Ruling
Wholly unsecured junior mortgage on debtor's residence could stripped off.
Procedural posture

Plaintiff Chapter 7 debtor filed an adversary proceeding against defendant mortgage company, seeking a determination that a junior mortgage the company held on the debtor's residence could be stripped off pursuant to 11 U.S.C.S. § 506 because it was wholly unsecured. The parties filed cross-motions for summary judgment on the debtor's claim.

ABI Membership is required to access the full summary of Smoot v. Wachovia Mortg. (In re Smoot) Please sign in if you are already an ABI member, or otherwise you may Become an ABI Member

Consumer opinion summary, case decided on November 01, 2011 , LexisNexis #1111-115

Chism v. Bank of Am. (In re Chism)

Ruling
Wholly secured junior mortgage was subject to strip off.
Procedural posture

Plaintiff Chapter 13 debtor filed a complaint against defendant, the holder of a second mortgage lien on debtor's real property, pursuant to 11 U.S.C.S. § 506(a) and Fed. R. Bankr. P. 3012, to determine the validity of the holder's lien.

ABI Membership is required to access the full summary of Chism v. Bank of Am. (In re Chism) Please sign in if you are already an ABI member, or otherwise you may Become an ABI Member

Consumer opinion summary, case decided on October 14, 2011 , LexisNexis #1111-077