Geo. D. Warthen Bank v. Tony Tillman

CourtDistrict Court, M.D. Georgia
DecidedFebruary 17, 2026
Docket5:25-cv-00428
StatusUnknown

This text of Geo. D. Warthen Bank v. Tony Tillman (Geo. D. Warthen Bank v. Tony Tillman) is published on Counsel Stack Legal Research, covering District Court, M.D. Georgia primary law. Counsel Stack provides free access to over 12 million legal documents including statutes, case law, regulations, and constitutions.

Bluebook
Geo. D. Warthen Bank v. Tony Tillman, (M.D. Ga. 2026).

Opinion

IN THE UNITED STATES DISTRICT COURT FOR THE MIDDLE DISTRICT OF GEORGIA MACON DIVISION GEO. D. WARTHEN BANK, Appellant, CIVIL ACTION NO. v. 5:25-cv-00428-TES

TONY TILLMAN, Appellee.

ORDER AFFIRMING BANKRUPTCY COURT

Before the Court is Geo. D. Warthen Bank’s (the “Bank”) appeal of the United States Bankruptcy Court’s denial of its effort to dismiss Tony Tillman’s Chapter 13 bankruptcy case. Specifically, the Bank asserts two grounds of error. See [Doc. 6, Appellant’s Brief, p. 1]. First, it argues the Bankruptcy Court erred in holding Tillman complied with the provisions of his bankruptcy plan and 11 U.S.C. § 1325(a)(5)(C) by surrendering any rights and legal claims he had to certain collateral—even though he did not physically deliver the collateral. [Id.]. Second, the Bank argues the Bankruptcy Court erred in failing to dismiss the case under (1) 11 U.S.C. § 1307(c)(6) for “material default by the debtor with respect to a term of a confirmed plan”; (2) 11 U.S.C. § 1307(c)(1) for “unreasonable delay that is prejudicial to the creditor”; and (3) 11 U.S.C. § 1307 generally for cause. [Id.]. For the reasons set forth below, the Court AFFIRMS the Bankruptcy Court’s order denying the Bank’s motion to dismiss. FACTUAL BACKGROUND AND PROCEDURAL HISTORY

Tillman filed for Chapter 13 bankruptcy on November 18, 2024. [Doc. 2, p. 1]. He filed a previous Chapter 13 bankruptcy case in 2023 that included the same loans at issue in this case, which were secured by his 2006 John Deere backhoe, a gooseneck

trailer, and a 2005 Triton crappie boat (collectively, the “Collateral”). [Doc. 4, p. 3]. In that previous bankruptcy case, Tillman proposed to “surrender” (and, as explained below, that term is important) the same three items of collateral, and the Bankruptcy

Court confirmed the plan. [Id. at p. 4]. After plan confirmation in the 2023 bankruptcy case, the Bank filed an adversary proceeding objecting to the dischargeability of Tillman’s debts. [Id.]. However, the Bankruptcy Court dismissed the 2023 bankruptcy case after it granted the trustee’s motion to dismiss for Tillman’s failure to make the

required payments. [Id.]. The dismissal obviated any need for the Bankruptcy Court to resolve the issue presented in the adversary proceeding. [Id.]. The main argument in the Bank’s earlier adversary proceeding a centered around

Tillman’s inability to provide the location of the Collateral and its belief that he filed for bankruptcy in bad faith. [Id.]. This, of course, is critical to the arguments presented in this appeal. Via the Bank’s prior adversary proceeding in the 2023 bankruptcy case, it knew that Tillman—during that case—couldn’t locate the Collateral. It is also worth

noting that in February 2023, a few months before the commencement of the previous bankruptcy case, the Bank approved another loan to Tillman for the repair of the backhoe. [Id. at p. 3]. The Bank’s representative testified that the Bank approved the

loan without physically seeing the backhoe. [Id. at p. 10]. Fast forward a year to November 2024, when Tillman filed a new Chapter 13 case—this one. [Id. at p. 4]. Like his 2023 bankruptcy case, his 2024 bankruptcy plan also

provided for a surrender of the Collateral—the same Collateral for which the Bank previously knew Tillman couldn’t provide a location, and the same Collateral the Bank didn’t ask to physically see when it renewed his last loan. [Id.]. After filing his petition

and before the Bankruptcy Court confirmed the current Chapter 13 plan, Tillman moved for an extension of the automatic stay so he could again search for the Collateral. [Doc. 2, p. 2]. Importantly, the Bank did not object. [Id.]. And just like in his 2023 bankruptcy case, Tillman couldn’t find the Collateral or even provide an address for it.

[Doc. 6, Appellant’s Brief, p. 7]. The Bankruptcy Court then held a hearing on plan confirmation, pursuant to 11 U.S.C. § 1324. [Doc. 2, p. 2]. Under the confirmation hearing statute, “[a] party in interest may object to the

confirmation of the plan.” 11 U.S.C. § 1324(a). Although Tillman had demonstrated once again that he had no idea where the Collateral was, neither the Bank nor any other creditor objected, and the Bankruptcy Court predictably approved the plan. [Doc. 2, p. 2]. A little over two months later, the Bank moved to dismiss. [Id. at p. 3]. The

Bankruptcy Court continued the hearing for the motion to dismiss multiple times by agreement of the parties to allow Tillman more time to search and provide a location for the Collateral. [Doc. 6, Appellant’s Brief, p. 2]. After the hearing, the Bankruptcy Court

orally announced its decision to deny the Bank’s motion. [Doc. 2, p. 4]. Following the Bankruptcy Court’s Order Denying Motion to Dismiss, the Bank filed a Notice of Appeal pursuant to Federal Rule of Bankruptcy Procedure 8002. [Id. at pp. 4–5].

DISCUSSION A. Standard of Review “The district court in a bankruptcy appeal functions as an appellate court in

reviewing [a] bankruptcy court’s decision.” Williams v. EMC Mortg. Corp. (In re Williams), 216 F.3d 1295, 1296 (11th Cir. 2000) (per curiam). The Court must “review [its] bankruptcy court’s factual findings for clear error and its legal conclusions de novo.” Fla. Agency for Health Care Admin. v. Bayou Shores SNF, LLC (In re Bayou Shores SNF,

LLC), 828 F.3d 1297, 1304 (11th Cir. 2016). B. Chapter 13 Plan Confirmation and Waiver of Post-Confirmation Arguments

Chapter 13 proceedings are intended to adjust the debts of an individual by creating a payment plan that is satisfied through the party’s regular, future income. In re Kitchens, 702 F.2d 885, 887 (11th Cir. 1983). The debtor makes payments to a bankruptcy trustee who then disperses the funds to creditors until all debts have been satisfied under the confirmed plan. United States v. Devall, 704 F.2d 1513, 1515–16 (11th Cir. 1983). The debtor also has the option to surrender any collateral securing the claim to the debtor rather than include that claim under a payment plan. See 11 U.S.C. §§ 1325(a)(5)(B)–(C). In addition to the debtor surrendering collateral or entering a

payment plan, the claim will be allowed if the creditor accepts the plan. Id. at § 1325(a)(5)(A). Bankruptcy courts are required to hold a hearing for the Chapter 13 plan confirmation where “[a] party in interest may object to confirmation of the plan.”

Id. at § 1324(a). They will then confirm or deny the plan under the confirmation statute. See id. at § 1325. Here, the Court must necessarily decide the issues surrounding waiver and

argument preclusion. Parties are not permitted to “relitigat[e] issues that were or could have been raised in” an action resulting in “a final judgment on the merits of the action.” Allen v. McCurry, 449 U.S. 90

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Geo. D. Warthen Bank v. Tony Tillman, Counsel Stack Legal Research, https://law.counselstack.com/opinion/geo-d-warthen-bank-v-tony-tillman-gamd-2026.