In Re: Mongiello

CourtCourt of Appeals for the Second Circuit
DecidedMay 28, 2026
Docket25-934 (L)
StatusUnpublished

This text of In Re: Mongiello (In Re: Mongiello) is published on Counsel Stack Legal Research, covering Court of Appeals for the Second Circuit primary law. Counsel Stack provides free access to over 12 million legal documents including statutes, case law, regulations, and constitutions.

Bluebook
In Re: Mongiello, (2d Cir. 2026).

Opinion

25-934 (L) In re: Mongiello

UNITED STATES COURT OF APPEALS FOR THE SECOND CIRCUIT

SUMMARY ORDER

RULINGS BY SUMMARY ORDER DO NOT HAVE PRECEDENTIAL EFFECT. CITATION TO A SUMMARY ORDER FILED ON OR AFTER JANUARY 1, 2007, IS PERMITTED AND IS GOVERNED BY FEDERAL RULE OF APPELLATE PROCEDURE 32.1 AND THIS COURT’S LOCAL RULE 32.1.1. WHEN CITING A SUMMARY ORDER IN A DOCUMENT FILED WITH THIS COURT, A PARTY MUST CITE EITHER THE FEDERAL APPENDIX OR AN ELECTRONIC DATABASE (WITH THE NOTATION “SUMMARY ORDER”). A PARTY CITING TO A SUMMARY ORDER MUST SERVE A COPY OF IT ON ANY PARTY NOT REPRESENTED BY COUNSEL.

At a stated term of the United States Court of Appeals for the Second Circuit, held at the Thurgood Marshall United States Courthouse, 40 Foley Square, in the City of New York, on the 28th day of May, two thousand twenty-six.

PRESENT:

RICHARD J. SULLIVAN, JOSEPH F. BIANCO, ALISON J. NATHAN, Circuit Judges. _____________________________________

IN RE CHRISTOPHER MONGIELLO,

Debtor. _____________________________________

CHRISTOPHER MONGIELLO,

Debtor-Appellant,

v. Nos. 25-934 (L) 25-970 (Con) HSBC BANK USA, NA, as Trustee for the LMT 2006-6 Trust Fund, a.k.a. HSBC Bank USA NA, as Trustee for the Lehman Mortgage Trust Mortgage-Pass-Through Certificates Series 2006-6, INDYMAC BANK, F.S.B., SHELLPOINT MORTGAGE SERVICING, LLC,

Appellees. _____________________________________

For Debtor-Appellant: CHRISTOPHER M. MONGIELLO, pro se, Pelham Manor, NY.

For Appellees: Leisl Kerechek, Stradley Ronon Stevens & Young, LLP, New York, NY.

Appeal from a judgment of the United States District Court for the Southern

District of New York (Kenneth M. Karas, Judge).

UPON DUE CONSIDERATION, IT IS HEREBY ORDERED,

ADJUDGED, AND DECREED that the March 31, 2025 judgment of the district

court is AFFIRMED.

Christopher M. Mongiello, proceeding pro se, appeals from the district

court’s judgment affirming the dismissal of his voluntary Chapter 13 petition and

related adversary proceedings by the bankruptcy court. On appeal, Mongiello

argues that the dismissal was improper because he (i) timely filed necessary

documents with the bankruptcy court and (ii) litigated in good faith. He also

2 contends that the bankruptcy court abused its discretion by dismissing his

adversary proceedings because judicial economy, convenience to the parties,

fairness, and comity supported retaining those cases. See In re Porges, 44 F.3d 159,

163 (2d Cir. 1995). We assume the parties’ familiarity with the underlying facts,

procedural history, and issues on appeal, to which we refer only as necessary to

explain our decision.

I. Background

In October 2023, Mongiello filed a voluntary Chapter 13 petition and two

related adversary proceedings to extinguish mortgages on his condominium; he

also sought to obtain damages from HSBC Bank USA, NA, Indymac Bank, and

Shellpoint Mortgage Servicing, LLC. In time, Mongiello’s ex-wife, Tiffany

Eastman – whom a state court had appointed receiver of the condo – moved to lift

the Chapter 13 case’s automatic stay to sell the property. The bankruptcy court

ultimately granted that motion and denied Mongiello’s multiple attempts to

vacate its decision. Undeterred, Mongiello countered with a motion to remove

Eastman as receiver, a request to obtain discovery from her, and a motion to hold

her in contempt.

While those motions were pending, the bankruptcy court granted the

U.S. Trustee’s and Eastman’s motion to dismiss the Chapter 13 proceeding on the 3 grounds that Mongiello caused unreasonable delay by failing to submit necessary

information and by litigating in bad faith in the bankruptcy proceeding. It also

dismissed the adversary proceedings because they were premised on the

bankruptcy case and denied Mongiello’s motion against Eastman as moot. The

district court affirmed the bankruptcy court’s orders, In re Mongiello, Nos. 24-cv-

2468, 24-cv-2548 (KMK), 2025 WL 959174, at *7 (S.D.N.Y. Mar. 31, 2025), and

Mongiello timely appealed to this Court.

II. Discussion

“When reviewing a bankruptcy court decision that was subsequently

appealed to a district court, we review the bankruptcy court’s decision

independent of the district court’s review,” In re Coudert Bros., 673 F.3d 180, 186

(2d Cir. 2012), and “disturb a dismissal for cause only if the bankruptcy court has

abused its discretion,” In re Murray, 900 F.3d 53, 59 (2d Cir. 2018); see also In re C-TC

9th Ave. P’ship, 113 F.3d 1304, 1312 & n.6 (2d Cir. 1997) (reviewing dismissal for

bad faith under the abuse-of-discretion standard and underlying “factual

conclusions of bad faith under the clearly erroneous standard”). And “we liberally

construe pleadings and briefs submitted by pro se litigants, reading such

submissions to raise the strongest arguments they suggest.” McLeod v. Jewish Guild

4 for the Blind, 864 F.3d 154, 156 (2d Cir. 2017) (alteration adopted, internal quotation

marks omitted, and italicization added).

A. The Bankruptcy Court Acted Within Its Discretion in Dismissing Mongiello’s Bankruptcy Petition.

The bankruptcy court offered two bases for dismissing Mongiello’s

bankruptcy case: first, it found “unreasonable delay by the debtor that is

prejudicial to creditors,” In re Mongiello, No. 23-bk-22732, Doc. No. 81, at 5 (Bankr.

S.D.N.Y. Mar. 13, 2024) (quoting 11 U.S.C. § 1307(c)(1)); and second, it concluded

that Mongiello had acted in bad faith – i.e., abused the bankruptcy process – when

he provided insufficient and inaccurate documents to the court and pursued

baseless grounds for relief against his ex-wife. Because we agree that Mongiello

acted in bad faith, we need not consider whether Mongiello also unreasonably

delayed the proceedings.

“A bankruptcy court may dismiss a bad faith filing on an interested party’s

motion or sua sponte.” In re C-TC 9th Ave. P’ship, 113 F.3d at 1310; see also

Marrama v. Citizens Bank of Mass., 549 U.S. 365, 372–73, 375 n.12 (2007) (noting that

bankruptcy court may sua sponte dismiss Chapter 13 case “for cause”). Our cases

have found that a debtor files a petition in bad faith when he proceeds on false or

baseless claims, see In re 60 E. 80th St. Equities, 218 F.3d 109, 117 (2d Cir. 2000)

5 (“[B]ad faith may be inferred from the meritlessness of a motion.”), or with the aim

of collaterally attacking the judgment of another court rather than trying to repay

his debts, see In re C-TC 9th Ave. P’ship, 113 F.3d at 1310 (affirming a bankruptcy

court decision which concluded that filing a petition “to avoid the consequences

of adverse state[-]court decisions” is “an impermissible use” of the bankruptcy

process (internal quotation marks omitted)).

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