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Fourth Circuit Holds In Chapter 13, Good-Faith Review May Consider Pre-Filing Accumulation of Secured Debt

In a published opinion, the Fourth Circuit affirmed the denial of confirmation of an above-median Chapter 13 debtor’s plan that proposed to pay off three recently purchased vehicles while paying unsecured creditors less than eight cents on the dollar. In Goddard v. Burnett, No. 25-1303 (4th Cir. Apr. 28, 2026), the court held that technical […]

• Good Faith
• Means Test Deductions

Tags: 1325(a)(3), 1325(b), bankruptcy, BAPCPA, chapter 13, confirmation, disposable income, good faith, luxury vehicles, means test, Secured Debt

April 28, 2026

Appellee’s brief – Goddard

In re Goddard 4th Cir Opinion

Ninth Circuit Allows Emotional Distress Damages for Violation of Section 524(i)

In an unpublished memorandum disposition, the Ninth Circuit affirmed a Bankruptcy Appellate Panel decision reviving Chapter 13 debtors’ claim that their mortgage creditors violated the discharge injunction by failing to properly credit payments made under their confirmed plan. In Valdellon v. PHH Mortgage Corp., No. 25-538 (9th Cir. Apr. 20, 2026), the court held that […]

• Cure
• Discharge Injunction
• Finality of Discharge
• Jurisdiction
• Sanctions

Tags: 3002.1, 524(i), bankruptcy, Taggart

9th Circuit BAP Opinion

9th Circuit opinion – Valdellon

Valdellon v. PHH Mortg. Corp. (In re Valdellon) – BAP opinion

April 27, 2026

Valdellon v Wells Fargo – Appellee’s brief – 9th Circuit

Valdellon v Wells Fargo – Appellant’s Reply brief – 9th Circuit

Valdellon v Wells Fargo – Appellant’s brief – 9th Circuit