By William Houston Brown, U.S. Bankruptcy Judge, Memphis (Retired) and Lawrence R. Ahern, III, Brown & Ahern (Nashville, TN)
Background
An earlier, two-part comment in this "unintended consequences" series examined subprime consumer title-pawn lenders, who were granted the ability to object to a Chapter 13 plan -- merely by virtue of having filed a motion for relief from the stay -- in the Eleventh Circuit's decision in Title Max v. Northington (In re Northington).2 Now, the Ninth Circuit has allowed a trustee . . .
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