From the Editor – Conversion and Dismissal

By The Honorable William Houston Brown (Retired)

Dismissal affirmed of case filed by marijuana grower. The Tenth Circuit Bankruptcy Appellate Panel affirmed dismissal of a Chapter 7 case filed by a licensed Colorado marijuana grower and the denial of conversion to Chapter 13. The bankruptcy court found cause to dismiss since the Chapter 7 or 13 trustee could not lawfully administer the debtor’s marijuana assets. Notwithstanding legalization of marijuana in Colorado, it remains a federal crime. Confirmation of a Chapter 13 plan based on income from federal criminal conduct would not be permitted. Cause for . . .

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