In re: Armida Castaneda Ramirez

CourtUnited States Bankruptcy Appellate Panel for the Ninth Circuit
DecidedMay 20, 2025
Docket24-1123
StatusUnpublished

This text of In re: Armida Castaneda Ramirez (In re: Armida Castaneda Ramirez) 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
In re: Armida Castaneda Ramirez, (bap9 2025).

Opinion

FILED MAY 20 2025

NOT FOR PUBLICATION SUSAN M. SPRAUL, CLERK U.S. BKCY. APP. PANEL OF THE NINTH CIRCUIT

UNITED STATES BANKRUPTCY APPELLATE PANEL OF THE NINTH CIRCUIT

In re: BAP Nos. EC-24-1122-SGC ARMIDA CASTANEDA RAMIREZ, EC-24-1123-SGC Debtor. (Related Appeals)

FERMIN CASTANEDA, Bk. No. 19-23509 Appellant, v. Adv. Nos. 19-02075 J. MICHAEL HOPPER, Chapter 7 23-02057 Trustee, Appellee. MEMORANDUM*

Appeal from the United States Bankruptcy Court for the Eastern District of California Christopher M. Klein, Bankruptcy Judge, Presiding

Before: SPRAKER, GAN, and CORBIT, Bankruptcy Judges.

Memorandum by Judge Spraker.

Concurrence by Judge Gan.

INTRODUCTION

Fermin Castaneda appeals two judgments entered in separate

adversary proceedings. The first appeal challenges the entry of a corrected judgment that avoided chapter 7 1 debtor Armida Castaneda Ramirez’s

transfer of her interest in real property in Springfield, Virginia

(“Property”), to Castaneda. The second appeal arises from a trial in a

subsequent adversary proceeding where the chapter 7 trustee sued

Castaneda for a breach of a prepetition Property Settlement and Support

Agreement (“Marital Settlement”) executed with Ramirez. The trustee also

sought turnover of the Property and authority to sell the Property.

Castaneda raises the same central issue in both appeals: the scope of

relief the court originally awarded in 2020, when it avoided the debtor’s

prepetition transfer of the Property. In the first appeal, Castaneda contends

that the court erred by entering the corrected judgment years after the

avoidance action to clarify that the estate had recovered Ramirez’s interest

subject to the avoided transfer. He argues that the court did not—and

legally could not—provide for the trustee’s “recovery” of the transferred

interest. The record, however, amply demonstrates that the trustee sought,

and the court intended, to avoid and recover the transferred interest for the

benefit of the estate. Because the court was well within its discretion to

correct the judgment in the first adversary to make plain that the estate not

only avoided but also recovered the debtor’s interest in the Property, we

1 Unless specified otherwise, all chapter and section references are to the Bankruptcy Code, 11 U.S.C. §§ 101–1532, all “Rule” references are to the Federal Rules of Bankruptcy Procedure, and all “Civil Rule” references are to the Federal Rules of Civil Procedure.

2 AFFIRM the Corrected Judgment.

As for Castaneda’s appeal from the judgment entered in the

subsequent adversary proceeding, the bankruptcy court found that the

trustee had failed to prove any of his claims. Though the court found that

Castenda had defaulted on his obligation under the Marital Settlement to

timely pay the mortgage on the Property, it also concluded that no

damages resulted. The court effectively entered judgment for Castaneda on

that claim because he cured the default before trial. Because Castaneda

prevailed at trial, there is no relief available to him on appeal. Though he

disagrees with various findings made by the bankruptcy court, none of the

challenged findings appear to be a necessary or conclusive part of the

judgment. As a result, nothing he has raised would affect the judgment

entered in the second adversary proceeding even if he were to prevail as to

the challenged findings. Accordingly, the second appeal must be

DISMISSED as moot.

FACTS2

A. The first adversary proceeding.

Ramirez and Castaneda were married and owned the Property as

tenants by the entirety. In December 2018, they entered into the Marital

Settlement, which addressed child custody and support, the division of

2 We exercise our discretion, when appropriate, to take judicial notice of documents electronically filed in the underlying bankruptcy case and adversary proceeding. See Atwood v. Chase Manhattan Mortg. Co. (In re Atwood), 293 B.R. 227, 233 n.9 (9th Cir. BAP 2003). 3 assets, the debts of the parties and other terms of their separation. The

Marital Settlement provided that the parties would incorporate its terms

into any divorce action that might be later filed. The record is unclear

whether a divorce was ever filed; no judicial records have been provided to

establish any divorce proceeding.

Pertinent to these appeals, Castaneda agreed to give Ramirez sole

custody of the couple’s minor children, and not to challenge her relocation

to California with the children. In turn, Ramirez agreed that Castaneda

would have exclusive, but temporary, possession of the Property.

Paragraph 9 of the Marital Settlement provided for the eventual sale of the

Property when “the parties mutually agree to sell their marital residence.”

Upon any sale, the Marital Settlement required that Ramirez and

Castaneda split the net sale proceeds evenly without restriction. However,

so long as Castaneda continued to occupy the Property,

Husband shall be responsible and liable for the principal, interest, taxes, and insurance on any mortgages or Deeds of Trust relating to the ownership of said property, in their entireties, including any deficiency judgments pertaining thereto, and shall indemnify and hold Wife harmless thereon. Furthermore, Husband shall be solely responsible for all utility expenses, maintenance costs, and repairs of the property, and shall indemnify and hold Wife harmless thereon.

Despite the Marital Settlement, in February 2019, Ramirez signed a

General Warranty Deed conveying her 50% interest in the Property to 4 Castaneda (“2019 Deed”). Castaneda gave no consideration for the transfer

of Ramirez’s interest in the Property.

Ramirez filed bankruptcy shortly thereafter in May 2019. Hopper was

appointed to serve as chapter 7 trustee (“Trustee”). Within weeks of the

bankruptcy filing, Trustee sued Castaneda under § 548 for avoidance of the

fraudulent transfer arising from the 2019 Deed and under § 550(a)(1) for

recovery of the transferred interest, or the value of such transferred interest

(the “2019 Action”).

The 2019 action was tried by the bankruptcy court in October 2020.

Castaneda claimed that the 2019 Deed was not avoidable because Ramirez

did not transfer anything of meaningful value to him. Castaneda reasoned

that the Marital Settlement continued to remain in full force and effect, and

governed the parties’ rights, interests, and duties with respect to the

Property. According to Castaneda, Ramirez’s Marital Settlement rights

were property of the estate, thus the 2019 Deed to Castaneda did not

transfer any property to him.

In its oral findings of fact and conclusions of law following trial, the

bankruptcy court discussed the Marital Settlement, including the parties’

rights and the agreement to sell the Property at a mutually agreeable time.

The court noted Castaneda’s arguments that there was no evidence at trial

to establish the estate would ultimately recover sufficient value to warrant

a sale of the Property. Citing Hyman v.

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In re: Armida Castaneda Ramirez, Counsel Stack Legal Research, https://law.counselstack.com/opinion/in-re-armida-castaneda-ramirez-bap9-2025.