Bank of America National Trust & Savings Ass'n v. Hanger (In Re Hanger)

217 B.R. 592, 98 Daily Journal DAR 1547, 39 Collier Bankr. Cas. 2d 677, 98 Cal. Daily Op. Serv. 1277, 1997 Bankr. LEXIS 2176, 1997 WL 837514
CourtUnited States Bankruptcy Appellate Panel for the Ninth Circuit
DecidedNovember 17, 1997
DocketBAP No. CC-97-1179-OHaJ, Bankruptcy No. SA 96-19988 LR
StatusPublished
Cited by26 cases

This text of 217 B.R. 592 (Bank of America National Trust & Savings Ass'n v. Hanger (In Re Hanger)) is published on Counsel Stack Legal Research, covering United States Bankruptcy Appellate Panel for the Ninth Circuit primary law. Counsel Stack provides free access to over 12 million legal documents including statutes, case law, regulations, and constitutions.

Bluebook
Bank of America National Trust & Savings Ass'n v. Hanger (In Re Hanger), 217 B.R. 592, 98 Daily Journal DAR 1547, 39 Collier Bankr. Cas. 2d 677, 98 Cal. Daily Op. Serv. 1277, 1997 Bankr. LEXIS 2176, 1997 WL 837514 (bap9 1997).

Opinion

OPINION

OLLASON, Bankruptcy Judge. '

Bank of America National Trust and Savings Association (“bank”) appeals an order allowing Dale and Sandra Hanger (“Debtors”) to avoid its judicial lien in its entirety. The bank contends that its lien only partially impaired Debtors’ homestead exemption and that § 522(f) 2 would allow the partial avoidance of the lien. We REVERSE and REMAND.

STATEMENT OF FACTS

The pertinent facts are undisputed.

Debtors filed a voluntary Chapter 7 on August 26, 1996. Debtors owned a home which the bankruptcy court determined was worth $270,000, according to Debtor’s subsequent appraisal. Debtors claimed a $75,000 homestead exemption pursuant to California law which was not contested.

On November 11, 1996, Debtors filed a motion to avoid judicial liens impairing their homestead exemption. The total liens on the property, rounded off and in order of their priority, was as follows:

Consensual lien................$158,000
Pacific Alternator judicial lien ... 3,817
Bank of America judicial lien____ 92,565
Wells Fargo judicial lien........ 32,843

The bank objected to the motion and requested a hearing. Based on their calculations, the lien of Pacific Alternator could not be avoided, and the bank’s lien could be partially avoided.

Debtors replied that a lien which impairs the homestead exemption “in any way whatsoever” can be avoided in its entirety.

The hearing took place on February 25, 1997, at which tíme the bankruptcy court determined the property value of $270,000, which the bank has accepted for purposes of this appeal. Applying § 522, the bankruptcy court made calculations as follows:

(1) adding the consensual lien and the exemption yielded a sum of $233,000 ($158,000 + $75,000);
*594 (2) subtracting $233,000 from the property value of $270,000 yielded an equity of $37,000;
(3) taking the first priority judicial lien of Pacific Alternator of $3,800: that lien could not be avoided because it was less than the total equity;
(4) subtracting $3,800 from $37,000 yielded an equity balance of $33,200;
(5) taking the Bank’s lien of $92,600: that lien exceeded the equity balance by $59,400 3 ($92,600 - $33,000). In other words there was only enough equity to secure the $92,600 hen up to $33,000.

The bankruptcy court noted that prior to the Bankruptcy Reform Act of 1994 and the amendment to § 522, the court would be allowed to avoid part of a lien and let part of a hen survive. (Citing In re Chabot, 992 F.2d 891 (9th Cir.1993)). Since Congress intended for the amendment to overrule Char bot, the court concluded that the full value of the Bank’s hen was avoidable if it impaired the exemption at all. The court also determined that the third priority hen of Wells Fargo was avoidable in its entirety. Separate orders avoiding each hen were entered on March 19,1997. The Bank timely appealed.

ISSUE

Whether the resulting calculation under § 522(f)(2) to determine the “extent that [the Bank’s] hen impair[ed] an exemption” required the avoidance of the bank’s hen in its entirety.

STANDARD OF REVIEW

This appeal raises questions of statutory interpretation which are reviewed de novo. In re Higgins, 201 B.R. 965, 966 (9th Cir. BAP 1996).

DISCUSSION

Section 522(f)(1) provides that a debtor may avoid the fixing of judicial hen “on an interest of the debtor in property to the extent that such hen impairs an exemption to which the debtor would have been entitled under subsection (b) of this section.” Section 522(f)(2) provides a means to calculate how a hen impairs the exemption, as follows:

(2)(A) For the purposes of this subsection, a hen shall be considered to impair an exemption to the extent that the sum of—
(i) the hen,
(ii) ah other hens on the property; and
(Hi) the amount of the exemption that the debtor could claim if there were no hens on the property;
exceeds the value that the debtor’s interest in the property would have in the absence of any hens.

11 U.S.C. § 522 (1994) (emphasis added).

The debtor’s avoiding power is limited “in that it may be employed ‘only to the extent that the hen impairs the debtor’s exemption.’ ” 4 Collier on Bankruptcy § 522.11[1] at 522-74 (15th ed.1997). Section 522(f)(1) was not intended to free the debt- or’s property of judicial hens altogether; rather it was intended to preserve the debt- or’s exemption. The legislative history of this section provides:

Subsection (f) protects the debtor’s exemptions, his discharge, and thus his fresh start by permitting him to avoid certain hens on exempt property. The debtor may avoid a judicial hen on any property to the extent that the property could have been exempted in the absence of the hen.

H.R.Rep. No. 595, 95th Cong., 1st Sess. 362 (1977); S.Rep. No. 989, 95th Cong., 2d Sess. 76 (1978), reprinted in 1978 U.S.C.C.A.N. 5787, 6318.

Section 2 was added in 1994 to define the words “impair an exemption” in § 522(f)(1). “This amendment would provide a simple arithmetic test to determine whether a hen impairs an exemption, based upon a decision, In re Brantz, 106 B.R. 62 (Bankr.E.D.Pa.1989), that was favorably cited by the Supreme Court in Owen v. Owen, 500 U.S. 305, 313, n. 5, 111 S.Ct. 1833, 1838, n. 5, 114 *595 L.Ed.2d 350 (1991).” H.R.Rep. 103-834, 103rd Cong., 2nd Sess. 35-37 (October 4, 1994); 140 Cong.Rec. H10769 (Oct. 4, 1994). See In re Wilson, 90 F.3d 347, 350 (9th Cir.1996) (subsection 522(f)(2)(A) sets forth a formula to determine whether a lien impairs an exemption).

Applying this formula to the facts of this case, we can determine that the bank’s lien impairs Debtors’ exemption:

Sum of: the lien...............$ 92,565
all other liens.......... 158,000
......... 3,817
......... 32,843
the exemption......... 75.000

Free access — add to your briefcase to read the full text and ask questions with AI

Related

Untitled Case
N.D. California, 2026
Philip Dean Mannlein
D. Idaho, 2024
Louie Esquivel Salazar
C.D. California, 2022
Richard Chiu v. Mike Rosen
Ninth Circuit, 2018
In re: Richard Chiu
Ninth Circuit, 2017
In re Dickey
517 B.R. 5 (D. Massachusetts, 2014)
In re Derocha
503 B.R. 553 (D. Rhode Island, 2014)
In Re Heaney
453 B.R. 42 (E.D. New York, 2011)
All Points Capital Corp. v. Meyer (In Re Meyer)
373 B.R. 84 (Ninth Circuit, 2007)
In Re Levinson
372 B.R. 582 (E.D. New York, 2007)
In Re Kanakaris
341 B.R. 33 (S.D. California, 2006)
In Re White
337 B.R. 686 (N.D. California, 2005)
Milgard Tempering, Inc. v. Darosa (In Re Darosa)
318 B.R. 871 (Ninth Circuit, 2004)
In Re Vokac
273 B.R. 553 (N.D. Illinois, 2002)
In Re Ware
274 B.R. 206 (D. South Carolina, 2001)
In Re Salanoa
263 B.R. 120 (S.D. California, 2001)
In Re Cisneros
257 B.R. 332 (D. New Mexico, 2000)
Katz v. Pike (In Re Pike)
243 B.R. 66 (Ninth Circuit, 1999)

Cite This Page — Counsel Stack

Bluebook (online)
217 B.R. 592, 98 Daily Journal DAR 1547, 39 Collier Bankr. Cas. 2d 677, 98 Cal. Daily Op. Serv. 1277, 1997 Bankr. LEXIS 2176, 1997 WL 837514, Counsel Stack Legal Research, https://law.counselstack.com/opinion/bank-of-america-national-trust-savings-assn-v-hanger-in-re-hanger-bap9-1997.