In re: Liduvina de Jesus Rivera

CourtUnited States Bankruptcy Court, D. Puerto Rico
DecidedAugust 8, 2024
Docket21-03520
StatusUnknown

This text of In re: Liduvina de Jesus Rivera (In re: Liduvina de Jesus Rivera) is published on Counsel Stack Legal Research, covering United States Bankruptcy Court, D. Puerto Rico primary law. Counsel Stack provides free access to over 12 million legal documents including statutes, case law, regulations, and constitutions.

Bluebook
In re: Liduvina de Jesus Rivera, (prb 2024).

Opinion

IN THE UNITED STATES BANKRUPTCY COURT 1 FOR THE DISTRICT OF PUERTO RICO 2 3 IN RE: CASE NO. 21-03520 (MCF) 4

5 LIDUVINA DE JESUS RIVERA

6 Debtor Chapter 7 7

9 OPINION AND ORDER 10 11 The Debtor, Liduvina de Jesus Rivera, is requesting a stay pending appeal of our order 12 converting her chapter 13 case to a chapter 7 and requiring the chapter 13 trustee to pay 13 accumulated post-petition homeowners association (HOA) fees that were due and not paid by 14 the Debtor as part of her living expenses (Docket No. 259).1 This expense is customarily listed as part of ongoing monthly expenses on Part 2, number 4d of Schedule J reflected as homeowner’s 15 association or condominium dues. Our order reads as follows: 16 17 Given that the Debtor agrees to a chapter 7 conversion (Docket No. 220 at 10), the case is hereby converted to chapter 7. The 18 Chapter 13 Trustee is ordered to retain funds to pay the 19 homeowner's association its administrative claim for post- petition fees of $290.00 monthly for 31 months (December 2022 20 through June 2024), a total of $8,990.00 (Docket No. 190 at 7). Section 1326(a)(2) of the Bankruptcy Code provides that if a plan 21 is not confirmed, the trustee is to return all plan payments to 22 the debtor, after deducting any unpaid claim allowed under 11 U.S.C. § 503(b). 11. U.S.C. § 1326(a)(2). In Harris v. Viegelahn, 23 135 S. Ct. 1829 (2015), the Supreme Court of the United States ruled that in a confirmed chapter 13 case that converts to 24 chapter 7, the trustee’s service is terminated upon conversion 25 with no duty, right, or ability to distribute to creditors any funds that are still held on hand, pursuant to 11 U.S.C. § 348(e). 26

27 1 The case initiated with two debtors. Co-Debtor, Miguel Angel Elvira Santana’s case was dismissed after he passed away and counsel requested a voluntary dismissal (Docket Nos. 206 and 235). The surviving spouse, Liduvina de However, we point out that the Harris decision is not applicable 1 in the instant case since here we have a conversion before 2 confirmation. Thus, we direct the trustee to pay such expenses before returning payments to the Debtor. 3 Docket No. 224.

4 5 This is the Debtor’s third unsuccessful chapter 13 bankruptcy since 2017 and she has 6 accumulated quite a large amount of pre-petition (HOA) fee arrears in the amount of $22,451.88 7 over a property that she claims as her residence (Claim No. 7-2). The Debtor has failed to pay any 8 post-petition HOA fees since the filing of her latest bankruptcy petition under the guise of proposing that the chapter 13 trustee pay the same through the plan (Docket Nos. 2, 48 and 190). 9 The chapter 13 trustee, from the minutes of the 341 meeting of creditors to present (for more 10 than two and a half years), has required the Debtor to clarify exactly how he was to pay the HOA 11 fees and what amount was to be paid (Docket Nos. 27, 31, 50, 59, 86, 96, 100, 128, 142, 149, 155, 12 163, 171 and 192) The Debtor ultimately responded to the trustee’s reiterated request for 13 clarification by stating that (1) the HOA claim will be paid in the amount claimed on Claim No. 7- 14 2 (even though the Debtor should know that the claim is for pre-petition amounts and not post- 15 petition amounts); (2) that she is correctly proposing in her plan to pay the HOA after all fees and 16 secured claims, which means no payment until at least May 2025; and (3) the HOA, as an 17 unsecured creditor, is not entitled to payment before confirmation of the plan (Docket No. 214). 18 The court issued an order to show cause as to why the case should not be dismissed for 19 failure to pay post-petition HOA fees (Docket No. 197). The Debtor responded by saying that the 20 creditor had not opposed the treatment reflected in the plan, that as a general unsecured 21 creditor it was not entitled to receive pre-confirmation payment and that it was not entitled to 22 receive payment as an administrative claim because it had not requested it nor provided any 23 legal support for it (Docket No. 218). We point out that as early as March 2, 2022, the HOA filed a motion to dismiss in which it objected to the Debtor’s proposed treatment under the plan, lack 24 of inclusion of the HOA fees in Schedule J as a monthly living expense and for failure to pay HOA 25 as an administrative expense (Docket Nos. 20 and 21). Since the inception of the bankruptcy 26 case, the HOA has vigorously prosecuted its HOA fees regarding post-petition monthly fees and 27 whether its claim for pre-petition fees would be allowed with a secured status. We will consider the stay pending appeal under Fed. R. Bankr. P. 8007. A court has 1 substantial discretion to grant or deny a stay pending appeal on such terms as it may deem 2 appropriate, subject to an abuse of discretion standard of review. In re Target Graphics, Inc., 372 3 B.R. 866 (Bankr. E.D.Tenn. 2007). In deciding whether a stay is warranted, a court must consider: 4 “(1) whether the appellant has established a strong showing of likelihood of success on the 5 merits; (2) whether the appellant will be irreparably harmed if the stay is denied; (3) whether a 6 stay will injure the other party; and (4) where the impact on the public interest lies.” Elias v. 7 Sumski (In re Elias), 182 F. App'x 3, 4 (1st Cir. 2006) (citing Acevedo-Garcia v. Vera-Monroig), 296 8 F.3d 13, 16 (1st Cir. 2002). The movant bears the “heavy” burden of satisfying each of the four 9 factors. In re GMC, 409 B.R. 24 (Bankr. S.D.N.Y. 2009). If a party fails to satisfy any one of the 10 four requirements for a stay pending appeal, then the court will be acting within its discretion to deny the stay. In re Dakota Rail, Inc., 111 B.R. 818, 820 (Bankr. D. Minn. 1990). Nonetheless, as 11 expressed by the U.S. District Court for the District of Puerto Rico in a case requesting a stay 12 pending appeal: 13 14 the first two factors ‘are the most critical.’ Nken v. Holder, 556 U.S. 418, 434 (2009). Because both of these factors ‘require a showing of more than mere 15 possibility,’ the movants ’must show a strong likelihood of success, and they must demonstrate that irreparable injury will be likely absent . . . [a stay].’ 16 Respect Maine PAC v. McKee, 622 F.3d 13, 15 (1st Cir. 2010). 17 Candelario-Del Moral v. UBS Fin. Servs., 290 F.R.D. 336, 345 (D.P.R. 2013). 18

19 20 Likelihood of Success on the Merits 21 The Debtor is appealing our order which converts the case to chapter 7 and orders the 22 trustee to pay post-petition HOA fees. She now requests that the bankruptcy court stay the 23 effects of the same; however, her likelihood of success on the merits is low. 24 Regarding the conversion to chapter 7, the Debtor argues that the case should not have 25 been converted even though she stated that upon the death of the co-debtor, she was unable to 26 continue with the chapter 13 case and that wished to convert the case to one under chapter 7. 27 However, in the ultimate delay tactic, she said that she would need more time to file the she expressly stated in her motion that she agreed to conversion to chapter 7, the court would 1 not allow the Debtor to continue to delay and highjack the bankruptcy process to avoid paying 2 the monthly post-petition HOA fees in addition to all other creditors already subjected to 3 unreasonable delay. Stevenson v TND Homes I LP, 583 B.R.

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Related

Nken v. Holder
556 U.S. 418 (Supreme Court, 2009)
Elias v. Sumski (In Re Elias)
182 F. App'x 3 (First Circuit, 2006)
In Re General Motors Corp.
409 B.R. 24 (S.D. New York, 2009)
In Re Dakota Rail, Inc.
111 B.R. 818 (D. Minnesota, 1990)
Harris v. Viegelahn
575 U.S. 510 (Supreme Court, 2015)
Respect Maine Pac v. McKee
622 F.3d 13 (First Circuit, 2010)
Stevenson v. TND Homes I, LP (In re Stevenson)
583 B.R. 573 (First Circuit, 2018)
Vázquez Morales v. Caguas Federal Savings & Loan Ass'n of P.R.
118 P.R. Dec. 806 (Supreme Court of Puerto Rico, 1987)
Candelario-Del Moral v. UBS Financial Services Inc.
290 F.R.D. 336 (D. Puerto Rico, 2013)

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In re: Liduvina de Jesus Rivera, Counsel Stack Legal Research, https://law.counselstack.com/opinion/in-re-liduvina-de-jesus-rivera-prb-2024.