In re: Lorraine Robinson

CourtDistrict Court, E.D. Louisiana
DecidedMarch 27, 2026
Docket2:24-cv-00487
StatusUnknown

This text of In re: Lorraine Robinson (In re: Lorraine Robinson) is published on Counsel Stack Legal Research, covering District Court, E.D. Louisiana primary law. Counsel Stack provides free access to over 12 million legal documents including statutes, case law, regulations, and constitutions.

Bluebook
In re: Lorraine Robinson, (E.D. La. 2026).

Opinion

UNITED STATES DISTRICT COURT EASTERN DISTRICT OF LOUISIANA

IN RE: LORRAINE ROBINSON CIVIL ACTION

NO: 24-0487

SECTION: C (5)

ORDER AND REASONS

Before the court is the appeal of an order of the United States Bankruptcy Court for the Eastern District of Louisiana, denying a motion to vacate sanctions imposed for violating the automatic stay provided by 11 U.S.C. § 362(a). The order is AFFIRMED. FACTUAL AND PROCEDURAL HISTORY In December 2019, the debtor, Lorraine Robinson, suffered a stroke that left her partially disabled. Her brother, Johnnie Robinson, assumed her care, including managing a rental property at 3426-3428 South Liberty Street in New Orleans. The Liberty Street property consists of six units and was Lorraine’s primary source of income. In June, 2020, Lorraine granted power of attorney to Robinson who then assisted her in filing Chapter 13 bankruptcy to protect the Liberty Street property.

Lorraine died in January, 2023 and Robinson proceeded with the bankruptcy. In February 2023, Jonathan Burden appeared at the Liberty Street property and asserted that he owned it. Robinson did not know Burden. Burden told Robinson

that Lorraine signed a quitclaim deed conveying the property to him. Burden returned to the property in March, 2023. This time police were called. Robinson told police and Burden about the pending bankruptcy. After reviewing

Burden’s quitclaim deed and records on the Parish Tax Assessor’s website, the police told Robinson to leave the property. Robinson initiated an adverse bankruptcy proceeding against Burden, Zero Three Four Investment Group, and David Alfortish, who notarized the quitclaim

deed. 23-1011, Rec. Doc. 1. Robinson sought a declaration that the quitclaim deed was null, enforcement of the automatic stay, return of the Liberty Street property, and an award of attorney fees and sanctions for violating the automatic stay. In

response, Burden filed a state court action against Robinson’s attorney seeking protection “from stalking or sexual assault.” Burden’s state court lawsuit was ultimately dismissed for lack of prosecution. In the adverse bankruptcy proceeding, Robinson filed a Motion for

Emergency Enforcement of Automatic Stay, for Temporary Restraining Order, and/or for Preliminary Injunction Against Defendant/Creditor, Jonathan Burden, and Motion for Emergency Enforcement of Automatic Stay for Protective Order, and/or

for Preliminary Injunction Against State Court Filings, by Defendant/Creditor, Jonathan Burden, Against Plaintiff and/or Plaintiff’s Counsel. 23-1011, Rec. Docs. 8 and 9. Robinson sought an emergency injunction against Burden as well as

sanctions, fees, and costs for violating the automatic stay. An emergency hearing was held, but Burden did not appear. The bankruptcy court preliminarily granted Robinson’s motions. 23-1011, Rec. Doc. 15. The court

found service of process on Burden and his corporation proper. The court further found the automatic stay applicable to the Liberty Street property and the rents. Burden was enjoined from exercising possession of the Liberty Street property. The bankruptcy court then held an evidentiary hearing to consider the motions

on a final basis. 23-1011, Rec. Doc. 20. Alfortish appeared, but only on his own behalf. Again, Burden did not appear. The court again found service of process on Burden, Zero Three Four Investment Group, and Alfortish setting the evidentiary

hearing proper. The court confirmed its preliminary emergency findings, and further found Burden’s acts to possess the Liberty Street property willfully violated the automatic stay. Robinson’s motions were granted, and Burden was sanctioned under 11 U.S.C. § 362(k). The court took under advisement the amount of damages and

sanctions to be awarded. 23-1011, Rec. Doc. 20. The bankruptcy court instructed Robinson’s attorney to file verified invoices reflecting the time and costs to prosecute the violation of the automatic stay. Counsel complied. 23-1011, Rec. Docs. 22 and 23. Burden was given the opportunity to respond, but filed no response.

In a Memorandum Opinion and Order, the bankruptcy court awarded Robinson $4,650 for rents that were uncollected on the Liberty Street property, as well as $20,016 in attorney fees and $134.82 in expenses. Burden was also

sanctioned $1,976 in attorney fees and $80 in expenses in favor of Robinson’s attorney related to the state court lawsuit Burden filed against him personally. The bankruptcy court found these awards reasonable given the seriousness of the stay violations, the harm caused to the bankruptcy estate and creditors, the timely

responses of Robinson and his attorney to protect the bankruptcy estate, and the prevailing rates for legal services. Burden was ordered to appear for a compliance hearing. Despite notice, he

neither appeared nor paid the sanctions. For his non-compliance, Burden was held in civil contempt. 23-1011, Rec. Doc. 31. Burden then filed a Motion to Vacate Orders and for Leave of Court to File Pleadings In State Court Relative to the Subject Property of this Bankruptcy Matter.

23-1011, Rec. Doc. 37. He claimed he did not receive any summons or notice of Robinson’s complaint. Thus, he asserted he was denied due process in connection with the orders and sanctions. Burden sought to vacate all bankruptcy orders and leave to file pleadings in state court relative to ownership of the Liberty Street property.

Robinson opposed the motion to vacate and submitted evidence of service at 2023 Peniston Street, New Orleans. 23-1011, Rec. Doc. 72. In a sworn affidavit attached to his motion to vacate, Burden admitted that address as his residence. 23-

1011, Rec. Doc. 46. Burden then filed a second affidavit asserting: “The Adversary Complaint was filed on May 17, 2023, but I did not move to 2023 Peniston Street until after my mother’s surgery, in September 2023 which is why I never received notice of the

complaint.” 23-1011, Rec. Doc. 71. Robinson countered, arguing the evidence shows 2023 Peniston St. as Burden’s “dwelling or usual place of abode” and the location where he “regularly conducts a business or profession.” See Fed. Rule Bkrtcy. Proc.

7004(b)(1). 23-1011, Rec. Doc. 78. The bankruptcy court denied the motion to vacate, finding Burden received adequate notice. 23-1011, Rec. Doc. 97. Burden appealed. 23-1011, Rec. Doc. 100; 24-0487, Rec. Doc. 1.

LAW AND ANALYSIS Burden argues the bankruptcy court erred in imposing sanctions. Robinson contends Burden seeks to address the merits and overturn the original sanctions

judgment, but only appealed the denial of the subsequent motion to vacate. Thus, he argues Burden’s appeal is late. He also argues the bankruptcy court did not err in denying the motion to vacate.

This court has appellate jurisdiction pursuant to 28 U.S.C. § 158. The standard of review is the same used by an appellate court reviewing a district court proceeding. In re Killebrew, 888 F.2d 1516, 1519 (5th Cir. 1989). Accordingly, this

court must review conclusions of law de novo, findings of fact for clear error, and mixed questions of law and fact de novo. In re Nat’l Gpsum Co., 208 F.3d 498, 504 (5th Cir. 2000). A district court will only reverse a bankruptcy court’s fact findings if, upon review of the entire record, the court is left with the “definite and firm”

conviction that the bankruptcy court erred.

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