From the Editor – Dismissal

By The Honorable William Houston Brown (Retired)

Trustee must recoup confirmed plan payments distributed after case dismissal. Construing § 349’s effect of dismissal, the court found the reasoning of Harris v. Viegelahn applicable, with dismissal ending the case and the trustee’s authority to disburse funds to creditors. The trustee was required to recoup post-dismissal disbursed funds so that they could be returned to the debtor. In re Bateson, _________B.R.________, 2016 WL 3475613 (Bankr. E.D. Mich. 2016).

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The Honorable William Houston Brown retired in 2006 as a . . .

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