By The Honorable William Houston Brown (Retired)
(Judge Brown prepares quarterly updates of consumer law developments for the Federal Judicial Center, which circulates the updates to bankruptcy judges.)
Applicable commitment period applies to debtors with no projected disposable income. The Ninth Circuit, en banc, overruled one aspect of Maney v. Kagenveama (In re Kagenveama), 541 F.3d 868 (9th Cir. 2008), holding that § 1325(b)(1)(B) requires for confirmation that the length of the plan must be at least equal to § 1325(b)(4)’s applicable commitment period. Even . . .
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