In Re Patenaude

259 B.R. 481, 45 Collier Bankr. Cas. 2d 1487, 2001 Bankr. LEXIS 275, 2001 WL 277698
CourtUnited States Bankruptcy Court, D. Massachusetts
DecidedMarch 19, 2001
Docket19-10268
StatusPublished
Cited by1 cases

This text of 259 B.R. 481 (In Re Patenaude) is published on Counsel Stack Legal Research, covering United States Bankruptcy Court, D. Massachusetts primary law. Counsel Stack provides free access to over 12 million legal documents including statutes, case law, regulations, and constitutions.

Bluebook
In Re Patenaude, 259 B.R. 481, 45 Collier Bankr. Cas. 2d 1487, 2001 Bankr. LEXIS 275, 2001 WL 277698 (Mass. 2001).

Opinion

MEMORANDUM OF DECISION

HENRY J. BOROFF, Bankruptcy Judge.

Before this Court is the “Debtor’s Amended Motion to Avoid Judicial Liens and Determine Claims to be Unsecured Claims” (the “Motion”). The Motion seeks to void a judicial hen held by Rugg Lumber Company, Inc. (“Rugg”) in the amount of $51,837.26 pursuant to 11 U.S.C. § 522(f). The lien is asserted against only the interest of the debtor Eugene F. Pate-naude (the “Debtor”) in the residence owned by him and his nondebtor spouse, as tenants by the entirety. In its opposition, Rugg argues that because, under Massachusetts law, each tenant by the entirety holds no separate interest in the subject property, § 522(f)(1)(A) 1 is inapplicable to a lien attaching to the interest of only one such owner.

I. FACTS AND BACKGROUND

The Debtor in this case filed a Chapter 7 case in this court on March 13, 2000. On Schedules A and D, the Debtor reported a residence owned with his nondebtor spouse, as tenants by the entirety, and located at 129 Blackberry Lane, Amherst, Massachusetts (the “Residence”). The *482 Debtor valued the Residence at approximately $190,000, 2 and described two mortgages on the property totaling $101,057.35, each held by Northampton Cooperative Bank. Pursuant to 11 U.S.C. § 522(b)(2), the Debtor elected the exemptions available under state law, including the $100,000 homestead exemption under Mass. Gen. L. ch. 188, § l. 3

The Debtor subsequently filed the instant Motion, requesting, inter alia, that a certain judicial lien in the sum of $51,837.26 issued by the Massachusetts District Court Division of the Trial Court, Franklin Division, dated February 9, 2000 and recorded in the Hampshire County Registry of Deeds on February 10, 2000 (the “Rugg Lien”) be voided pursuant to § 522(f). 4 Section 522(f)(2)(A) sets forth the formula used to calculate the extent to which a judicial lien impairs an exemption. 5 Employing the figures supplied by the Debtor, the formula would be applied as follows:

Property Value: $ 190,000.00
Rugg Lien: (51,837.26)
1st Mortgage: (82,303.51)
2nd Mortgage: (18,753.84)
Exemption: (100,000.00)
$ (62,894.61)

Based on the Debtor allegations, the mathematics would call for the voiding of the Rugg Lien, as the amount by which the Rugg Lien impairs the exemption exceeds the entire lien. However, Rugg filed an opposition alleging that the Debtor had undervalued the Residence. In Rugg’s view, the true value of the Residence was $217,300.00. If Rugg’s valuation was correct, the application of the § 522(f) formula would result in only partial impairment of the homestead exemption. The Rugg lien would not be fully avoided, but instead be reduced to the amount of $16,242.65.

A hearing was set on the Motion. At that hearing, Rugg asserted an additional defense. It argued that a judicial lien does not impair an exemption in a debtor’s interest in property unless the debtor has a present possessory (and not inchoate interest) in the property. Rugg argued that the Debtor here had no present interest in the Residence because, pursuant to M.G.L. c. 209, § 1, the Residence held by the Debtor and his nondebtor spouse was not subject to execution on the lien, so long as the Residence remained the principal residence of the Debtor and his spouse and they remain married.

In light of the fact that the nonimpairment theory advanced by Rugg would moot the valuation dispute, the Court took the former under advisement and deferred action on the latter.

II. DISCUSSION

Rugg points to two case threads to advance its non impairment theory. First, Rugg argues that a recent case in this District, In re Snyder, 231 B.R. 437 (Bankr.D.Mass.l999)(“Snyder I”), supports its position. In that case, the bankruptcy court held in a substantially similar case, that the extent of the § 522(f) im *483 pairment of that debtor’s exemption could not be established until the entireties tenancy was terminated. Accordingly, the court entered a provisional order based on the hypothesis that the debtor would subsequently become entitled to all of the property. However, the court raised the possibility of later reconsideration if the circumstances by which the tenancy ultimately terminated proved that hypothesis incorrect. Second, Rugg relies on two recent decisions out of the District of Maryland, In re Giles, 222 B.R. 766 (Bankr. D.Md.1998) and In re Carroll, 237 B.R. 872 (Bankr.D.Md.1999). In those cases, the Maryland bankruptcy court held that certain hens against the interest of only one owner in property held as tenants by the entirety should not be avoided because the hens attached to no present possessory interest of those debtors in the property. See Giles at 770.

Rugg’s reliance on both Snyder I and the foregoing Maryland cases is unwarranted. Snyder I was appealed to the First Circuit Bankruptcy Appellate Panel (the “BAP”). Snyder v. Rockland Trust Company, 249 B.R. 40 (1st Cir. BAP 2000) (“Snyder II”). In Snyder II, the BAP, affirming but modifying Snyder I, held that

the Debtor’s interest in the tenancy by the entirety property for the purposes of the section 522(f) formula should be valued at 100 percent. [However], the valuation should be ... fixed and not subject to a possible subsequent hearing when an event occurs which would terminate the tenancy by the entirety.

Id. at 46. In so holding, the BAP reasoned that finality was necessary both to assure honest debtors a fresh start and to determine the rights of the parties.

As for the Maryland cases, they are inapposite. The Giles and Carroll decisions implicated a state exemption statute which permitted neither attachment nor execution of liens against property held as a tenancy by the entirety, where the purported lien was asserted against only one, but not both owners. Accordingly, in each of Giles and Carroll, the bankruptcy court denied the request to avoid the lien under § 522(f) because avoidance was to no purpose. The debtor’s exemption was not impaired because the alleged lien did not impair the debtor’s postpetition use of the property.

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Bluebook (online)
259 B.R. 481, 45 Collier Bankr. Cas. 2d 1487, 2001 Bankr. LEXIS 275, 2001 WL 277698, Counsel Stack Legal Research, https://law.counselstack.com/opinion/in-re-patenaude-mab-2001.