In Bartenwerfer v. Buckley (In re Bartenwerfer), BAP No. NC-19-1178-TaFB (April 23, 2020), the Ninth Circuit Bankruptcy Appellate Panel ("BAP") held that the bankruptcy court correctly determined that all of the appellee's state court attorney's fees were non-dischargeable pursuant to 11 U.S.C. ยง 523(a)(2)(A).
Bankruptcy Courts Must Advise Creditors on the Scope of Discharge Injunctions
In In re John G. Moser, BAP No. NC-19-1094-FBTa (April 15, 2020), the Ninth Circuit Bankruptcy Appellate Panel ("BAP") held that the "return to the fray" doctrine requires bankruptcy courts to advise creditors on the scope of discharge injunctions.
