When Things Don’t Go According to (the) Plan – §1307(b) Voluntary Dismissals: Be Careful What You Ask For Part 2

By Mark C. Leffler1
click here for part 1
Part 1 explored the use by bad faith Chapter 13 debtors of § 1307(b) to seemingly escape the consequences of their bad faith. For years, the majority opinion was that § 1307(b) gave Chapter 13 debtors an absolute right to dismiss their bankruptcy cases. However, after the Supreme Court’s 2007 Marrama decision, which held that bad faith is a basis for denying Chapter 7 . . .

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