In Re Burt

378 B.R. 352, 58 Collier Bankr. Cas. 2d 1198, 64 U.C.C. Rep. Serv. 2d (West) 323, 2007 Bankr. LEXIS 3680, 2007 WL 4087071
CourtUnited States Bankruptcy Court, D. Utah
DecidedOctober 24, 2007
Docket07-23193
StatusPublished
Cited by19 cases

This text of 378 B.R. 352 (In Re Burt) is published on Counsel Stack Legal Research, covering United States Bankruptcy Court, D. Utah primary law. Counsel Stack provides free access to over 12 million legal documents including statutes, case law, regulations, and constitutions.

Bluebook
In Re Burt, 378 B.R. 352, 58 Collier Bankr. Cas. 2d 1198, 64 U.C.C. Rep. Serv. 2d (West) 323, 2007 Bankr. LEXIS 3680, 2007 WL 4087071 (Utah 2007).

Opinion

*354 MEMORANDUM DECISION

WILLIAM T. THURMAN, Bankruptcy Judge.

The matter before the Court is Ford Motor Credit Company, LLC’s (“Ford Motor Credit”) objection to confirmation of the Debtor’s proposed chapter 13 plan. Ford Motor Credit objects to confirmation on the basis that the Debtor’s proposed plan seeks to improperly cram down Ford Motor Credit’s secured claim in violation of 11 U.S.C. § 1325(a)(*), otherwise referred to as the “hanging paragraph.” The Debt- or filed a response to Ford Motor Credit’s objection and a separate objection to Ford Motor Credit’s proof of claim, arguing that § 1325(a)(*) does not apply to Ford Motor Credit’s claim because it does not hold a purchase money security interest (“PMSI”) in the 2006 Ford F-150 truck (the “Truck” or “vehicle”). Specifically, the Debtor argues that the financing of the service contract and the negative equity eliminated Ford Motor Credit’s PMSI, and therefore, Ford Motor Credit’s claim is subject to a cram down 1 under 11 U.S.C. § 506. 2 The Court determines that Ford Motor Credit’s entire claim, 3 including that portion of the claim attributable to negative equity and costs associated with the purchase of the vehicle, qualifies as a PMSI. Accordingly, the hanging paragraph of § 1325(a) applies, and the Debtor cannot “cram down” Ford Motor Credit’s claim pursuant to § 506. Therefore, the Debtor’s objection to Ford Motor Credit’s claim is overruled and the proposed plan is denied confirmation for failure to comply with § 1325(a).

I. BACKGROUND

Debtor, Darin L. Burt, filed a petition under Chapter 13 on July 13, 2007. On December 31, 2005, the Debtor purchased a 2006 Ford F-150 pickup truck for his personal use from LaPoint Automotive LLC (“LaPoint”). LaPoint financed the transaction through a Utah Simple Interest Retail Installment Contract (the “Contract”). Under the Contract, LaPoint retained a PMSI in the Truck. LaPoint later assigned its interest in the Truck to Ford Motor Credit, which perfected its security interest by notation on the Truck’s title as required by the Utah Motor Vehicle Act. 4

The Contract indicates that the cash price of the Truck was $32,630 and the total amount financed was $45,628.14. The difference between the two amounts included charges of $2,425 for a service contract, $500 for gap insurance, $298 for the document preparation fee, $1,149.46 for tax and license fees, and $11,021.68 to pay off the obligation owed on a trade-in vehicle (2004 Ford F-150). The negative equi *355 ty rolled into the transaction therefore is the $11,021.68 payoff less the Debtor’s down payment of $1,800 and the manufacturer’s rebate of $3,000, yielding a net negative equity 5 of $6,221. The evidence before the Court shows that because of the Debtor’s marginal credit, the Debtor was required to trade in his 2004 Ford F-150 in order to qualify for financing on the new vehicle. Furthermore, the evidence demonstrates that the Dealer would not have financed the purchase had the Debtor not agreed to all the terms of the Contract, including the refinancing of negative equity-

On August 30, 2007, Ford Motor Credit filed a proof of secured claim for its security interest in the Truck in the amount of $42,941.64. 6 Debtor filed his chapter 13 plan (the “Plan”) on July 25, 2007, which proposes to bifurcate Ford Motor Credit’s claim into a secured portion in the amount of $28,000 and an unsecured portion in the amount of the negative equity paid off by the financing transaction. Ford Motor Credit objected to confirmation of the Debtor’s plan on August 14, 2007, arguing that its entire claim qualified for treatment under the hanging paragraph of § 1325(a) and could not be bifurcated under § 506(a).

II. JURISDICTION AND VENUE

The Court has jurisdiction over this matter under 28 U.S.C. § 157(b)(2)(L). Venue is appropriate under 28 U.S.C. § 1408(1).

III. ANALYSIS

In order to obtain confirmation of a Chapter 13 plan, the debtor must comply with the provisions of 11 U.S.C. § 1325(a). Sections 506(a)(1) and 1325(a)(5) provide for the required treatment of secured creditors. Prior to the enactment of the Bankruptcy Abuse Prevention and Consumer Protection Act of 2005 (“BAPC-PA”), sections 506(a)(1) and 1325(a)(5)(B) allowed a Chapter 13 debtor to bifurcate an under secured creditor’s claim into se *356 cured and unsecured portions with the result that a creditor’s claim was allowed as secured only to the extent of the value of the collateral securing its debt. 7 The portion of the creditor’s claim allowed as secured would be paid in full with interest, whereas the unsecured portion of the claim would be paid pro rata with all other general unsecured claims. 8 This process of bifurcation is often referred to as “cram down.” 9 BAPCPA, however, amended § 1325 to give special protection to creditors who finance automobile transactions that occur within 910 days prior to the debtors’ filing for Chapter 13 relief. 10

Under BAPCPA, Congress added the “hanging paragraph” 11 after § 1325(a)(9), which prevents the bifurcation of certain secured claims. Specifically, the hanging paragraph states:

For purposes of paragraph (5), section 506 shall not apply to a claim described in that paragraph if the creditor has a purchase money security interest securing the debt that is the subject of the claim, the debt was incurred within the 910-day [sic] preceding the date of the filing of the petition, and the collateral for that debt consists of a motor vehicle (as defined in section 30102 of title 49) acquired for the personal use of the debtor, or if collateral for that debt consists of any other thing of value, if the debt was incurred during the 1-year period preceding that filing. 12

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Bluebook (online)
378 B.R. 352, 58 Collier Bankr. Cas. 2d 1198, 64 U.C.C. Rep. Serv. 2d (West) 323, 2007 Bankr. LEXIS 3680, 2007 WL 4087071, Counsel Stack Legal Research, https://law.counselstack.com/opinion/in-re-burt-utb-2007.