Mort Ranta and the Threshold Question of Jurisdiction: An Appealing Holding on Appellate Review

By Mark C. Leffler, Esquire,1 Boleman Law Firm, P.C., Richmond, VA

In its recent decision in Robert D. Mort Ranta v. Gorman, Trustee (In re Mort Ranta), --- F.3d ---, 2013 WL 3286252 (4th Cir. 2013), the 4th Circuit Court of Appeals considered whether debtors must commit their Social Security income in order meet the disposable income test of 11 U.S.C. § 1325(b). Ultimately, the court held that “for both above-median income and below-median income debtors, Social Security income is excluded from the calculation of ‘projected disposable . . .

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