From the Editor – Avoidance

By The Honorable William Houston Brown (Retired)

Judgment lien avoidable against debtor’s interest in entireties property. Considering the issue of whether a single-filing debtor may avoid a judgment lien against tenancy by entireties property, the court concluded that Maryland’s homestead exemption created an exception to the general rule seen in In re Alvarez, 733 F.3d 130 (4th Cir. 2013). Maryland had opted out of the § 522(d) exemptions, and its homestead exemption provided that the debtor “may exempt the debtor’s aggregate interest in. . .owner-occupied residential real property.”

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