From the Editor – Lien Stripping

By The Honorable William Houston Brown (Retired)

Untimely proof of claim did not void lien. Secured creditor’s lien was not void solely because creditor filed untimely proof of claim in Chapter 13 case. Debtors did not attack substantive validity of the lien, relying solely on section 506(d). Shelton v. Citimortgage, Inc. (In re Shelton), 735 F.3d 747 (8th Cir. 2013).

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The Honorable William Houston Brown retired in 2006 as a United States Bankruptcy Judge for the Western District of Tennessee, and he had been designated to sit also in the . . .

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