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Fraud and Abuse
CHAPTER 5-19: CIVIL REMEDIES FOR FRAUD AND ABUSE
Although criminal referrals play a crucial role in combatting bankruptcy
fraud and abuse, there are many civil remedies that can be invoked as well,
such as appointment of a trustee, denial of a discharge, or a bar from
refiling for an extended period of time. Civil remedies can be an effective
supplement to a criminal referral, particularly where limited resources make
criminal prosecution unlikely.
5-19.2 INITIAL REVIEW OF COMPLAINTS FOR CIVIL REMEDIES
Upon receipt of allegations of fraud or abuse in connection with a
bankruptcy, the United States Trustee should make an initial determination
as to whether there is a civil remedy available to address the alleged
misconduct. If so, the United States Trustee should proceed to conduct an
investigation appropriate for implementing a civil enforcement action.
5-19.3 COMMON ABUSES AND CIVIL REMEDIES: CHAPTER 7
5-19.3.1 Abuse: Bad Faith/Improper Purpose
5-22.214.171.124 Remedy: Dismissal Under 11 U.S.C. § 707(a) for "Cause"
- Lack of good faith constitutes cause. In re Zick, 931 F.2d 1124 (6th
Cir. 1991), lack of good faith is valid basis to dismiss chapter 7 case
"for cause" under section 707(a).
But see, In re Huckfeldt, 39 F.3d 829 (8th Cir. 1994), where case
sought to be dismissed under section 707(a), court's inquiry must be
framed in terms of whether "cause" existed for dismissal, and not in
terms of debtor's good or bad faith. However, cause exists where debtor
had an improper purpose for filing, i.e., to frustrate state court
divorce decree and push ex- wife into bankruptcy.
Michigan Credit Card Debt Lawyers
- Sufficient income to pay debts insufficient alone, but may be
combined with other factors. In re Cappuccetti, 172 B.R. 37 (Bankr. E.D.
Ark. 1994), showing of sufficient income to pay debts insufficient alone
to warrant dismissal under section 707(a), but when combined with other
factors, such as debtor reducing creditors to a single creditor in the
months prior to filing, continuing to live an expansive or lavish
lifestyle, filing in response to collection effort, etc., federal
government could prevail on a motion to dismiss on the grounds that the
petition was not filed in good faith. Michigan Credit Card Debt Attorneys
- Abuse of procedures. In re Hammonds, 139 B.R. 535 (Bankr. D. Colo.
1992), chapter 7 petition dismissed as not filed in good faith where
debtor had some ability to repay debts; had transferred nonexempt,
corporate assets to his non-debtor spouse without fair consideration;
had continuing comfortable lifestyle; had a deliberate and persistent
pattern of evading single major creditor; had provided less than candid,
full disclosure; and had engaged in "procedural gymnastics" in earlier
bankruptcy case. Michigan Credit Card Debt Lawyers
- Non-disclosure of previous filing. In re Burns, 169 B.R. 563 (Bankr.
W.D. Pa. 1994), dismissal of chapter 7 petition for cause justified
where debtor failed to disclose prior chapter 7 filing which included
all debts for which debtor was previously denied discharge.
5-126.96.36.199 Remedy: Dismissal Under 11 U.S.C. § 707(b) for "Substantial Abuse"
Other Than Debtor's Ability to Pay Debts
- Debtor must be honest, as well as non-needy. In re Veenhuis, 143 B.R.
887 (Bankr. D. Minn. 1992), although debtor had negative cash flow and
thus could not fund a chapter 13 plan, case could still be dismissed for
bad faith where other factors present, such as use of chapter 7 to
discharge single debt that debtor doesn't want to pay, failing to make a
sincere attempt to repay obligations, desire to repay only certain
creditors, tying up significant liquid value in superfluous exempt
assets, and financial troubles caused by past excesses rather than any
unforeseen calamity, all of which indicate debtor's "relationship with
creditors has [not] been marked by essentially honorable and undeceptive
dealings," quoting In re Krohn, 886 F.2d 123, 126 (6th Cir. 1989).
- Intent to stall or defeat creditors. In re Davidoff, 185 B.R. 631 (Bankr.
S.D. Fla. 1995), chapter 7 petition properly dismissed as bad faith
filing where court found that debtor did not seek fresh start, but
rather sought to retain affluent lifestyle at expense of creditors. Michigan Credit Card Debt Attorneys
5-188.8.131.52 Remedy: Sanctions
In re Boyd, 143 B.R. 237 (Bankr. C.D. Cal. 1992), Rule 9011 sanctions of
$22,500.09 (equal to moving party's costs) against debtor and debtor's
attorney, jointly and severally, justified both by fact that chapter 7
petition was filed "in bad faith and for an improper purpose" and under
alternative prong that petition was not well-grounded in fact and warranted
Michigan Credit Card Debt Lawyers
5-184.108.40.206 Remedy: Time Bar on Future Filing
Case law is split on whether the language "unless the court orders
otherwise" at the beginning of 11 U.S.C. § 349 modifies a later provision of
that same section that dismissal of a case does not prejudice a subsequent
petition "except as provided in section 109(g)." If so, the court could use
section 105 to order a bar exceeding 180 days.
- Cases holding the court can impose a bar under section 105 include:
In re Driscoll, 1988 WL 117303 (N.D. Ill.); In re Jolly, 143 B.R. 383 (E.D.
Va. 1992). See also, In re Strathatos, 163 B.R. 83 (N.D. Tex. 1993); In
re Earl, 140 B.R. 728 (Bankr. N.D. Ind. 1992); In re Dilley, 125 B.R.
189 (Bankr. N.D. Ohio 1991); Lerch v. Federal Land Bank of St. Louis, 94
B.R. 998 (Bankr. N.D. Ill. 1989); In re Hundley, 103 B.R. 768 (Bankr.
E.D. Va. 1989); In re McKissie, 103 B.R. 189 (Bankr. N.D. Ill. 1989).
- Cases holding the court cannot impose a bar under section 105
include: In re Frieouf, 938 F.2d 1099 (10th Cir. 1991), cert. denied,
502 U.S. 1091 (1992) (court could, however, deny discharge of scheduled
debts for a set period or even permanently); In re Cooper, 153 B.R. 898,
899 (D. Colo. 1993).
5-19.3.2 Abuse: Frivolous/Vexatious Litigation
5-220.127.116.11 Remedy: Injunction
In re Calder, 973 F.2d 862, 869 (10th Cir. 1992), appeals court held
district court justified in enjoining chapter 7 debtor from litigating
issues relating to those decided in its order so as to prevent the "misuse
of litigation," where district court found that debtor had attempted to
frustrate creditors and the trustee's efforts to close estate.
5-19.3.3 Abuse: Refiling after Previous Petition Dismissed "With Prejudice"
5-18.104.22.168 Remedy: Dismissal Based on Res Judicata
Colonial Auto Center, Inc. v. Tomlin, 184 B.R. 720 (W.D. Va. 1995), a
previous chapter 7 petition dismissed "with prejudice," has res judicata
effect of precluding subsequent discharge of debts existing at filing of
5-19.3.4 Abuse: Assertion of 5th Amendment by Debtor
5-22.214.171.124 Remedy: Dismissal if Assertion Precludes Administration of Estate
In re Moses, 792 F.Supp. 529 (E.D. Mich. 1992), dismissal appropriate
where debtor's refusal to testify, even though based upon validly asserted
5th Amendment privilege, precludes fair and effective administration of
In re Fekos, 148 B.R. 10 (Bankr. W.D. Pa. 1992), debtor's invocation of
5th Amendment as basis for refusal to answer questions at 2004 examination
did not warrant dismissal absent showing that refusal made it impossible for
trustee to administer the debtor's estates. Michigan Credit Card Debt Lawyers
5-19.3.5 Abuse: Fraudulently Incurred Credit Card DebtMichigan Credit Card Debt Attorneys
5-126.96.36.199 Remedy: Nondischargeability
In re Lee, 186 B.R. 695 (9th Cir. BAP 1995), BAP declines to follow
Manufacturer's Hanover Trust Co. v. Ward, 857 F.2d 1082 (6th Cir. 1988),
that, in order to establish that credit card debt was fraudulently incurred
and therefore nondischargeable, the credit card company must demonstrate
that it had performed a credit check sufficient to demonstrate implied or
express reliance on debtor's representations and ability and intent to
repay. Relying instead on factors enunciated in In re Dougherty, 84 B.R.
653, 656 (9th Cir. BAP 1988), the BAP stated that "a court may infer a
debtor's present intent not to repay future charges when at the time the
debtor incurs the charges he is insolvent and has no prospect of repayment."
186 B.R. at 699.
In re Eashai, 87 F.3d 1083 (9th Cir. 1996), Ninth Circuit adopts
Dougherty factors in case of credit card kiting, where debtor's intent to
deceive can be inferred from fact that cash advances were used to make
minimum payments on other credit cards to keep creditors at bay while
incurring ever larger debt.
5-19.3.6 Abuse: Violation of 11 U.S.C. § 110
5-188.8.131.52 Remedy: Sanctions
In re Cordero, 185 B.R. 882 (Bankr. M.D. Fla. 1995), sanction of $250
warranted for each of nonlawyer's three violations of statute governing
bankruptcy petition preparers.
In re Anthony J. Campanella, 207 B.R. 435 (Bankr. E.D. Pa. 1997), the
sale of bankruptcy kits alone does not constitute the unauthorized practice
of law and section 110 is not applicable because the lay person did not
assist in the preparation of the petition. The court held, however, that it
had authority to review the lay person's conduct pursuant to 11 U.S.C § 329
and Fed. R. Bankr. P. 2016 and 2017. The court found that the lay person's
activities surrounding the sale of the kits constituted the unauthorized
practice of law and enjoined him from selling kits in all jurisdictions in
which he was doing business.
United States Trustee v. Womack, 201 B.R. 511 (Bankr. E.D. Ark. 1996).
Section 110(a) applies even if the debtor intended the money paid to a
petition preparer be donated to another entity. The statute does not require
that a petition preparer benefit from the compensation received and a
petition preparer can not use payment to another entity as a mechanism to
avoid the statutory requirements. A petition preparer, however, who causes
another to sign the debtor's name to documents does not violate section
110(e)(1) because the section only prohibits petition preparers from
executing documents on behalf of debtors.
In re Kassa, 198 B.R. 790 (Bankr. D. Ariz. 1996), court held that
petition preparers compensation should be governed by a good legal
secretary's salary. Pursuant to section 110(h), the court reduced the
petition preparer's fee from $500 to $201.92.
5-19.3.7 Abuse: Concealed Assets
5-184.108.40.206 Remedy: Denial of Voluntary Dismissal
In re Churchill, 178 B.R. 478 (Bankr. D. Neb. 1995), chapter 7 debtor not
permitted to voluntarily dismiss case in attempt to avoid orderly
liquidation of assets and possible denial of discharge where trustee
discovered evidence of debtor's alleged concealment of assets.
5-19.4 COMMON ABUSES AND CIVIL REMEDIES: CHAPTER 11
5-19.4.1 Abuse: Bad Faith
Bad faith is a generic term that covers a wide range of misconduct. It
can be applied to acts ranging from prepetition misconduct to misstatements
made in connection with a filing to frivolous opposition to motions filed by
the United States Trustee or creditors. For this reason, there are numerous
remedies available to address it. Michigan Credit Card Debt Lawyer
5-220.127.116.11 Remedy: Dismissal
- New debtor syndrome. In re Trident Assoc. Ltd. Partnership, 52 F.3d
127 (6th Cir. 1995), bad faith dismissal affirmed where petition filed
by newly created debtor to which property was transferred on eve of
foreclosure; In re Spectee Group, Inc., 185 B.R. 146 (Bankr. S.D.N.Y.
1995), bad faith shown and sanctions ordered against debtor, its
president, and attorney where petition filed to frustrate creditor's
attempts to foreclose.
- Serial filing. In re Mableton-Booper Assoc., 127 B.R. 941 (Bankr.
N.D. Ga. 1991), serial chapter 11 filings permitted where unanticipated
change of circumstances since plan confirmation; however, where changed
circumstances were anticipated, later second filing to relieve debtor of
obligations under first plan constitutes bad faith; In re McCormick Road
Assoc., 127 B.R. 410 (N.D. Ill. 1991), bad faith established where,
after confirmation, debtor hired new counsel, made new filing, and then
found appraiser to prepare value estimate low enough to suit its
- Prior filings in other chapters and non-compliance. In re Smith, 144
B.R. 428 (Bankr. W.D. Ark. 1992), chapter 11 debtors' request for
additional time to file schedules denied and case dismissed with a
180-day bar for bad faith where debtors had filed successive chapters 12
and 13 "skeleton" petitions and failed to appear at section 341 meetings
or file schedules.
- Prepetition misconduct. In re Charfoos, 979 F.2d 390 (6th Cir.
1992), prepetition misconduct grounds for dismissal where misconduct
included misrepresentations on financial statements filed to obtain
loans prepetition, additional misrepresentations and nondisclosures in
the bankruptcy filing, a lavish lifestyle, and violation of a state
court order by selling some property and spending the $27,373 proceeds
in the month preceding bankruptcy.
5-18.104.22.168 Remedy: Bar on Refiling Exceeding 180-days
5-22.214.171.124 Remedy: Sanctions Under Rule 9011
- Sanctions mandatory for violation of Rule 9011. In re Gioioso, 979
F.2d 956 (3rd Cir. 1992).
- New debtor syndrome. In re Coones Ranch, Inc., 7 F.3d 740 (8th Cir.
1993), attorney fees disgorged and $10,000 sanctions imposed on debtor
- Improper purpose. In re Marsch, 36 F.3d 825 (9th Cir. 1994), debtor
sanctioned $27,452, the amount of attorneys' fees and costs incurred by
judgment creditor in fighting chapter 11 petition filed solely to keep
from posting appeal bond out of non-business assets; In re Phoenix Land
Corp., 164 B.R. 176 (Bankr. S.D. Fla. 1994), sanctions awarded where
chapter 11 case instituted solely to delay state court foreclosure.
5-126.96.36.199 Remedy: Sanctions Under Inherent Power of Bankruptcy Court
In re Rainbow Magazine, Inc., 77 F.3d 278 (9th Cir. 1996), in addition to
affirming inherent authority to sanction, the court indicated that its
holding in the case of In re Sequoia Auto Brokers, Ltd., 827 F.2d 1281 (9th
Cir. 1987), that the bankruptcy court lacked the authority to impose
contempt orders was, essentially, superseded by Congressional amendment of
Bankruptcy Rule 9020 which gives the bankruptcy court criminal contempt
authority; In re Aurora Investments, Inc., 144 B.R. 899 (Bankr. M.D. Fla.
1992); Chambers v. Naxco, Inc., 501 U.S. 32 (1991).
5-19.4.2 Abuse: Frivolous/Vexatious Litigation
5-188.8.131.52 Remedy: Sanctions
In re Courtesy Inns, Ltd., Inc., 40 F.3d 1084 (10th Cir. 1994), sanctions
against chapter 11 debtor's president upheld on appeal. Although bankruptcy
court lacked authority under 28 U.S.C. § 1927 to sanction a vexatious
litigant because it is not a "court of the United States," it did have
inherent authority to sanction debtor's president and sole shareholder who
made all filings on behalf of a lawyerless, insolvent corporation.
In re French Bourekas, Inc., 175 B.R. 517 (Bankr. S.D.N.Y. 1994), bad
faith not shown by mere fact that chapter 11 petition may have been filed to
relieve judgment debtor of need to post large supersedeas bond, but
sanctions could be assessed under 28 U.S.C. § 1927 against debtor's attorney
for "unreasonable and vexatious multiplication of proceedings," and also
ordered to pay $500 to court clerk.
In re United Markets Int'l., Inc., 24 F.3d 650 (5th Cir. 1994), upholding
district court order striking pleadings filed by debtor's principal, and
barring principal, who was also sole shareholder and an attorney, from
filing further pleadings until he paid more than $68,000 in sanctions
previously entered against him for vexatious litigation.
5-19.4.3 Abuse: Concealed Assets--Conversion from Chapter 7 to Chapter 11
After Discovery of Undisclosed Assets
5-184.108.40.206 Remedy: Reconversion/Appointment of Trustee
In re Finney, 992 F.2d 43 (4th Cir. 1994), upon discovery by chapter 7
trustee of debtor's undisclosed postpetition transfers with intent to
defraud creditors, debtor moved to dismiss, which was denied, and then moved
to convert to chapter 11. Circuit court held that bankruptcy court could
immediately reconvert, but only if reorganization found to be "objectively
futile." Circuit also noted that bankruptcy court had discretion to
determine whether a chapter 11 trustee should be immediately appointed.
5-19.4.4 Abuse: Unauthorized Practice of Law
5-220.127.116.11 Remedy: Disgorgement and Injunction
United States Trustee v. Kasuba, 152 B.R. 440 (Bankr. W.D. Pa. 1993), in
order to protect the public, bankruptcy court had equitable power to enjoin
certified legal technician from engaging in unauthorized practice of law in
violation of Pennsylvania statute and, despite disclaimer to the contrary,
legal technician could be required to disgorge fees under section 329 of the
Code. Note: In subsequent case, Stone v. Kasuba, 166 B.R. 269 (W.D. Pa.
1994), technician was held to be in contempt of the injunction order and was
sanctioned to disgorge all fees received for all bankruptcy petitions he had
5-19.4.5 Abuse: Unauthorized Filing
5-18.104.22.168 Remedy: Dismissal
Chitex Communications, Inc. v. Kramer, 168 B.R. 587 (S.D. Tex. 1994),
president of corporation placed in receivership had no authority to file
bankruptcy petition on corporation's behalf and, therefore, case dismissed.
5-22.214.171.124 Remedy: Rule 9011 Sanctions
In re Zaragosa Properties, Inc., 156 B.R. 310 (Bankr. M.D. Fla. 1993),
Rule 9011 sanctions awarded against attorney who filed unauthorized chapter
11 petition on behalf of corporation. Court noted that, even if
retroactively authorized by board, the filing was still unauthorized for
purposes of bankruptcy law.
5-19.5 COMMON ABUSES AND CIVIL REMEDIES: CHAPTER 13
5-19.5.1 Abuse: Failure to Attend Creditors' Meeting/Willful Disobedience
5-126.96.36.199 Remedy: Automatic 180-Day Bar
In re Montgomery, 37 F.3d 413 (8th Cir. 1994), where previous chapter 13
case dismissed for debtor's failure to attend creditors' meeting, dismissal
was inherently for "failure to abide by orders of the court," thus barring a
subsequent filing for 180 days under 11 U.S.C. § 109(g) and, in motion to
dismiss subsequent petition, debtor had burden of establishing that previous
conduct was not "willful." [Note: Court observed that some lower courts have
placed this burden on the moving creditor.]
5-19.5.2 Abuse: Bad Faith
5-188.8.131.52 Remedy: Dismissal Under 11 U.S.C. § 1307(c) and 180-Day Bar Under
11 U.S.C. § 109(g)
- Bad faith determined on totality of circumstances. In re Eisen, 14
F.3d 469 (9th Cir. 1993), dismissal for bad faith upheld based on
totality of circumstances, including that debtor filed two successive
chapter 13 petitions containing contradictory and misleading
descriptions of property, failed to disclose first filing in second
case, and filed second case on eve of state court enforcement action.
Court also imposed sanctions for frivolous appeal.
- Bad faith inferred from proposed plan. In re Love, 957 F.2d 1350
(7th Cir. 1992), bankruptcy court properly concluded that not only plan,
but entire chapter 13 case was filed in bad faith where tax protestor
proposed several plans that did not indicate serious intent to repay tax
In re Maurice, 167 B.R. 114 (Bankr. N.D. Ill. 1994), debtor's tactic
of mailing plan to incorrect location and neglecting to file plan,
together with unrealistic contents of plan, supports conclusion that
chapter 13 petition filed in bad faith to stave off enforcement of a
state court judgment without having to file a supersedeas bond and
dismissal for bad faith and sanctions against debtor and debtor's
5-184.108.40.206 Remedy: Sanctions
- Calculating amount when moving party is chapter 13 trustee. In re
Armwood, 175 B.R. 779 (Bankr. N.D. Ga. 1994), fifth chapter 13 case
filed in bad faith, justifying dismissal with 180- day bar and sanctions
payable to court clerk of $500 each against debtor (pursuant to court's
inherent authority) and debtor's attorney (pursuant to Rule 9011). In
calculating the amount of sanction, court observed that since chapter 13
trustee is "a salaried employee supervised by the United States Trustee
and serves a quasi-governmental function," assessment of attorneys fees
was not an appropriate measure of sanction, and instead used "level
appropriate to punish the participants and to deter future sanctionable
In re Peia, 145 B.R. 749 (Bankr. D. Conn. 1992), debtor found to have
improper purpose as evidenced by repeated filings without taking
appropriate steps towards confirming a plan could be sanctioned under
Rule 9011(a). Sanctions included compensation of chapter 13 trustee
based on time spent and reasonable rate calculation equalled $1,232,
plus additional $1,000 punitive sanction paid to court clerk.
- Sanctions awarded to moving creditor. In re Mergenthaler, 144 B.R.
632 (Bankr. E.D.N.Y. 1992), debtor sanctioned $8,000 separately and
$2,000 jointly and severally with attorney (both under Rule 9011) for
filing chapter 13 petitions for purpose of frustrating judgment
creditor's execution and for filing false affidavits and a false
declaration by attorney.
In re Standfield, 152 B.R. 528 (Bankr. N.D. Ill. 1993), sanction
awarded in amount of moving creditor's attorneys fees against debtors'
attorney where serial chapter 13 cases filed for sole purpose of
delaying pending foreclosure proceeding.
In re Huerta, 137 B.R. 356 (Bankr. C.D. Cal. 1992), court extensively
discusses law and policy relating to successive filings, concluding that
it is "a misuse of the bankruptcy process to file one case, then,
failing to achieve the intended goals, to refile a second case."
Sanctions in amount of creditor's attorney's fees awarded.
But see, In re Barker, 129 B.R. 287 (M.D. Fla. 1991), since debtor's
third chapter 13 case voluntarily dismissed before relief from stay
motion filed, debtor was not barred by Rule 109(g) from making fourth
filing and, therefore, debtor's signature on petition did not warrant
sanctions. Moreover, even if debtor had neither the ability nor
intention to file a feasible plan, this is not a valid basis for the
award of sanctions.
- Sanctions denied where burdensome on debtor's family. In re Jones,
174 B.R. 8 (Bankr. D.N.H. 1994), successive chapter 13 case dismissed as
bad faith filing, but no sanctions imposed on impecunious debtor in
order to "avoid penalizing debtor's family" and debtor would not be
barred from seeking bankruptcy relief for period of one year because the
injunction could easily be circumvented by having the debtor's wife
5-220.127.116.11 Remedy: Bar on Refiling Exceeding 180 Days
In re Gros, Jr., 173 B.R. 774 (Bankr. M.D. Fla. 1994), debtor's five
bankruptcy filings over two-year period caused unreasonable delay that
prejudiced collection efforts of Internal Revenue Service, justified
dismissal with two-year bar on refiling.
In re Stathatos, 163 B.R. 83 (N.D. Tex. 1993), district court affirms
bankruptcy court's order dismissing chapter 13 case for bad faith and
barring debtor from refiling under chapter 13 for 24 months.
In re Simmons, 149 B.R. 586 (Bankr. W.D. Mo. 1993), court dismissed chapter
13 petition filed by debtor who had filed one previous chapter 12 and two
previous chapter 13 petitions in order to defeat secured creditor's rights,
and enjoined debtor from further chapter 13 filings. Court also enjoined
debtor from refiling for a "reasonable period of time," which happened to be
set at 180 days, even though the bar was not imposed pursuant to section
But see, In re Frieouf, 938 F.2d 1099, supra; In re Cooper, 139 B.R. 736
(D. Colo. 1992), district court reversed imposition of three year bar,
relying on Frieouf.
5-18.104.22.168 Remedy: Conversion
In re Eatman, 182 B.R. 386 (Bankr. 1995), where debtor filed chapter 13
petition in bad faith and creditor moved to dismiss, court instead ordered
case converted in order to serve best interests of creditors and the estate.
Bankruptcy Basics - For Cases Filed on or after October 17, 2005 (pdf)
Basics - For Cases Filed before October 17, 2005 (pdf)
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