By The Honorable William Houston Brown (Retired)
Eligibility: Unsecured junior liens made debtors ineligible. Applying In re Scovis, 249 F.3d 975 (9th Cir. 2001), and looking to the debtors’ schedules, the Ninth Circuit held that three junior liens that were unsecured because of property value were included within the unsecured debt for eligibility, and the fact that the liens were voluntarily granted did not distinguish the case from Scovis. Santos v. Dockery (in re Santos), ___ Fed.Appx. _____, 2013 WL 51877213 (9th Cir. Sept. 17, 2013).
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