In re: Mark G. Reuss, Jr.

CourtUnited States Bankruptcy Court, W.D. Michigan
DecidedApril 12, 2011
Docket07-05279
StatusUnknown

This text of In re: Mark G. Reuss, Jr. (In re: Mark G. Reuss, Jr.) is published on Counsel Stack Legal Research, covering United States Bankruptcy Court, W.D. Michigan primary law. Counsel Stack provides free access to over 12 million legal documents including statutes, case law, regulations, and constitutions.

Bluebook
In re: Mark G. Reuss, Jr., (Mich. 2011).

Opinion

UNITED STATES BANKRUPTCY COURT FOR THE WESTERN DISTRICT OF MICHIGAN _______________________

In re:

MARK G. REUSS, JR., Case No. DT 07-05279 Chapter 7 Debtor. Hon. Scott W. Dales _____________________________________/

OPINION AND ORDER REGARDING DEBTOR’S MOTION TO HOLD CREDITOR IN CONTEMPT

PRESENT: HONORABLE SCOTT W. DALES United States Bankruptcy Judge

I. INTRODUCTION AND JURISDICTION

On March 16, 2011, in Traverse City, Michigan, the court held a hearing to consider the Debtor’s Motion for Finding of Violation of Discharge Injunction (the “Motion,” DN 110) against Wingspan Portfolio Advisors, LLC (“Wingspan”) and its agent, Essence Jefferson. The Motion arises from letters that Wingspan sent to the Debtor, Mark G. Reuss, Jr. (the “Debtor”), and his counsel, Thomas J. Budzynski, to make post-discharge arrangements to recover its collateral. This court has jurisdiction over the Debtor’s case pursuant to 28 U.S.C. §§ 157(a) and 1334(a). In addition, the court has inherent authority to enforce its orders. This contested matter is a core proceeding within the meaning of 28 U.S.C. § 157(b)(2)(O). The following constitutes the court’s findings of fact and conclusions of law in accordance with Bankruptcy Rules 7052 and 9014(c). As explained below, based upon the plain language of 11 U.S.C. § 524(a)(2) and the record (including the parties’ stipulations), the court finds that Wingspan did not violate the discharge injunction and therefore is not in contempt. II. ANALYSIS At the hearing, the parties agreed that the court could and should make its decision without conducting an additional evidentiary hearing. In addition, Debtor’s counsel1 further narrowed the issues by conceding that if any contempt occurred, it occurred when Wingspan sent

a letter dated December 3, 2010 (the “December Letter”) to Mr. Budzynski several months after Mr. Budzynski advised Wingspan that the Debtor intended to surrender Wingspan’s collateral. Mr. Luyt also advised the court that the Debtor was no longer seeking punitive damages, but only reasonable attorney fees for responding to the December Letter, filing the Motion, and appearing at the hearing.2 The court reviewed the moving and responsive papers, considered two letters admitted as exhibits, and heard oral argument. After permitting Debtor’s counsel to prepare an affidavit documenting reasonable attorney fees incurred because of the December Letter, the court took the matter under advisement. The parties generally agree about the following historical facts, but

differ as to the inferences the court should draw. The Debtor filed a voluntary petition for relief under Chapter 7 of the Bankruptcy Code on July 24, 2007 and received a discharge on or about December 10, 2007. The discharge relieved the Debtor of any personal liability on the debt secured by a mortgage on the property commonly known as 3926 Sean Robinson Ct., Traverse City, Michigan (the “Property”). The court, however, did not avoid or otherwise disturb the mortgage that Wingspan now seeks to enforce.

1 Gregory Luyt, as local counsel, argued the Motion for Mr. Budzynski, who maintains his office in the Eastern District of Michigan. 2 In its Motion, the Debtor originally requested $10,000.00 in costs, fees, and damages. At the hearing, Mr. Luyt narrowed this amount to reasonable attorney fees that accrued after August 18, 2010 and pertained to the December Letter. See Transcript of hearing held March 16, 2011 at p. 12, lines 13-25 to p. 13, lines 1-3. Several years later, Wingspan wrote to the Debtor and informed him that Wingspan was the new servicer of the mortgage on the Property. This was the only correspondence that Wingspan addressed directly to the Debtor. In August, 2010, however, Wingspan’s counsel called and wrote to Debtor’s counsel, Mr. Budzynski, concerning Wingspan’s foreclosure rights and inquiring about the Debtor’s intentions regarding the Property. Mr. Budzynski confirmed

for Wingspan, in writing, that the Debtor intended to surrender the Property, and that Wingspan should cease contact with the Debtor or face a motion for violating the discharge injunction. However, in Wingspan’s December Letter to Mr. Budzynski, the creditor inquired again about the Debtor’s intentions concerning the Property, and reiterated that its correspondence was not an attempt to collect the debt as the Debtor’s personal liability. Making good on his threat, Mr. Budzynski then filed the Motion, arguing that by sending the December Letter, Wingspan was attempting to collect a debt as a personal liability of the Debtor, in contempt of 11 U.S.C. § 524(a)(2) and the court’s discharge order. The issue before the court, as narrowed at the hearing, is whether Wingspan violated the

discharge injunction by sending the December Letter to Mr. Budzynski, thereby demonstrating contempt of the court and its injunction. The Bankruptcy Code provides that an order discharging the debtor “operates as an injunction against the commencement or continuation of an action, the employment of process, or an act, to collect, recover or offset any [discharged] debt as a personal liability of the debtor, whether or not discharge of such debt is waived.” 11 U.S.C. § 524(a)(2). Fundamentally, a discharge merely releases a debtor from personal liability on the discharged debt; when a creditor holds a mortgage lien or other interest to secure the debt, the creditor's rights in the collateral, such as foreclosure rights, survive or pass through the bankruptcy. See Tennessee Student Assistance Corp. v. Hood, 541 U.S. 440, 447 (2004) (“discharge order releases a debtor from personal liability with respect to any discharged debt”); Johnson v. Home State Bank, 501 U.S. 78, 82–83 (1991) (lien survives discharge). After the automatic stay terminates as to the property,3 a secured creditor may take any appropriate action to enforce a valid lien surviving the discharge, as long as the creditor does not pursue in personam relief against the debtor.

Because the discharge order operates as an injunction, the court may hold a creditor in contempt for violating its order. In re Roush, 88 B.R. 163, 164-65 (Bankr. S.D. Ohio 1988). Given the limits on bankruptcy court jurisdiction, however, the court generally regards such proceedings as civil rather than criminal in nature, compensatory and coercive rather than punitive. See In re Greenspan, 2011 WL 310703 (6th Cir. B.A.P. 2011) (recognizing right to damages and attorney fees if debtor establishes contempt of the discharge injunction, and citing cases). In a civil contempt proceeding, the movant must prove that the defendant “violated a definite and specific order of the court requiring him to perform or refrain from performing a

particular act or acts with knowledge of the court’s order.” Liberte Capital Group, LLC v. Capwill, 462 F.3d 543, 550 (6th Cir. 2006) (quoting Glover v. Johnson, 934 F.2d 703, 707 (6th Cir. 1991)).

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Caminetti v. United States
242 U.S. 470 (Supreme Court, 1917)
United States v. Ron Pair Enterprises, Inc.
489 U.S. 235 (Supreme Court, 1989)
Johnson v. Home State Bank
501 U.S. 78 (Supreme Court, 1991)
Tennessee Student Assistance Corporation v. Hood
541 U.S. 440 (Supreme Court, 2004)
In Re Downs
103 F.3d 472 (Sixth Circuit, 1996)
Liberte Capital Group, LLC v. Capwill
462 F.3d 543 (Sixth Circuit, 2006)
In Re Roush
88 B.R. 163 (S.D. Ohio, 1988)
Glover v. Johnson
934 F.2d 703 (Sixth Circuit, 1991)

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