From the Editor – Dismissal • NACTT Academy

From the Editor – Dismissal

By The Honorable William Houston Brown (Retired)

Dismissal with 180-day bar affirmed. The debtors had filed eight Chapter 13 cases over eight years, with each dismissed, and in 2019 the spouses filed three more cases. A mortgage creditor moved for relief from the automatic stay and dismissal in each of the cases. The cases were dismissed with a 180-day bar to refiling, because the purpose in these filings was to stop foreclosure, and the dismissals were not abuses of discretion. In re Steiner, __________B.R.__________, 2020 WL 1327211 (B.A.P. 8th Cir . . .

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