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Preventing Bankruptcy Fraud and Abuse

 

CHAPTER 5-19: CIVIL REMEDIES FOR FRAUD AND ABUSE


5-19.1 INTRODUCTION

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

5-19.3.1.1 Remedy: Dismissal Under 11 U.S.C. 707(a) for "Cause"

     

  1. 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.

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  2. 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

     

  3. 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

     

  4. 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.

     

5-19.3.1.2 Remedy: Dismissal Under 11 U.S.C. 707(b) for "Substantial Abuse" Other Than Debtor's Ability to Pay Debts

     

  1. 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).

     

  2. 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

     

5-19.3.1.3 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 by law.

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5-19.3.1.4 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.

 

  1. 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).

     

  2. 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

5-19.3.2.1 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"

5-19.3.3.1 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 dismissed case.

5-19.3.4 Abuse: Assertion of 5th Amendment by Debtor

5-19.3.4.1 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 estate.

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 Debt

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5-19.3.5.1 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

5-19.3.6.1 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

5-19.3.7.1 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

5-19.4.1.1 Remedy: Dismissal

  1. 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.

     

  2. 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 purposes.

     

  3. 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.

     

  4. 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.

     

5-19.4.1.2 Remedy: Bar on Refiling Exceeding 180-days

5-19.4.1.3 Remedy: Sanctions Under Rule 9011

     

  1. Sanctions mandatory for violation of Rule 9011. In re Gioioso, 979 F.2d 956 (3rd Cir. 1992).

     

  2. 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 and attorney.

     

  3. 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.

 

5-19.4.1.4 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

5-19.4.2.1 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

5-19.4.3.1 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

5-19.4.4.1 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 prepared.

5-19.4.5 Abuse: Unauthorized Filing

5-19.4.5.1 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.

5-19.4.5.2 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

5-19.5.1.1 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

5-19.5.2.1 Remedy: Dismissal Under 11 U.S.C. 1307(c) and 180-Day Bar Under 11 U.S.C. 109(g)

     

  1. 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.

     

  2. 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 debt.

    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 attorney.

     

5-19.5.2.2 Remedy: Sanctions

     

  1. 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 conduct."

    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.

     

  2. 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.

     

  3. 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 file.

     

5-19.5.2.3 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 109(g).

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.

5-19.5.2.4 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.


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