May, 2020 | Shulman Bastian Friedman & Bui LLP

Attorneys’ Fees Are Non-Dischargeable If They Are Traceable to Fraud

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...

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. The "return to the...