From the Editor – Lien Stripping

By The Honorable William Houston Brown (Retired)

Court could not strip lien on tenancy by entirety. In Chapter 13 filed by only one spouse, the debtor could not strip off lien with no value on property owned as tenants by entirety. The bankruptcy court lacked jurisdiction to modify a lienholder’s rights as to the non-debtor’s property interest. Alvarez v. Grigsby (In re Alvarez), 733 F.3d 136 (4th 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 . . .

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