• Sarah Little

Ninth Circuit also permits debtor to avoid lien without discharge


The U.S. Court of Appeals for the Ninth Circuit has held that a "chapter 20" debtor may avoid a first lien against the debtor's principal residence under Bankruptcy Code sections 506(a) and 1322(b)(2) even though no discharge was going to be entered in the debtor's chapter 13 case, as the creditor's claim had not been allowed. In re Blendheim, 803 F.3d 477 (9th Cir. 2015).


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