Filed 8/31/26 Lorenzetti v. Meer CA4/3
NOT TO BE PUBLISHED IN OFFICIAL REPORTS
California Rules of Court, rule 8.1115(a), prohibits courts and parties from citing or relying on opinions not certified for publication or ordered published, except as specified by rule 8.1115(b). This opinion has not been certified for publication or ordered published for purposes of rule 8.1115.
IN THE COURT OF APPEAL OF THE STATE OF CALIFORNIA
FOURTH APPELLATE DISTRICT
DIVISION THREE
ROBERT J. LORENZETTI,
Plaintiff and Appellant, G065793
v. (Super. Ct. No. 30-2015-
00814445)
RONALD L. MEER, OPINION
Defendant and Respondent.
Appeal from a postjudgment order of the Superior Court of Orange County, Julianne Sartain Bancroft, Judge. Affirmed.
FBFK Law, George L. Hampton, Stephanie A. Pittaluga and Christopher M. Kiernan for Plaintiff and Appellant.
Law Offices of Robert K. Kent and Robert K. Kent for Defendant and Respondent.
* * *
The underlying dispute in this case between plaintiff Robert J.
Lorenzetti and defendant Ronald L. Meer centers around payment for business consulting services. In 2017, Lorenzetti obtained an amended judgment for $390,609.88. Meer moved to stay enforcement against community property assets, contending that his wife’s 2014 bankruptcy discharge protected those assets. The trial court granted the motion, and Lorenzetti appeals. He argues that the discharge does not apply to judgments based on obligations that arose after the discharge.
We conclude that despite Lorenzetti’s attempts to establish otherwise, the debt at issue arose well before the bankruptcy petition or discharge. Accordingly, under the general rules that apply to community property in the context of bankruptcy, the Meers’ community property is not subject to collection. We find no error in the court’s ruling, and we therefore affirm the postjudgment order.
STATEMENT OF FACTS
A. Background Facts As of December 2008, Ronald Meer and his wife Jill1 owned and resided in a Newport Beach home. The Meers were experiencing financial difficulty and wished to sell the residence, which they listed for an asking price of $11.6 million. The residence was encumbered by three deeds of trust totaling over $10 million, all owed to the same bank. They were in arrears on all three loans.
In early December 2008, Ronald asked Lorenzetti, who had previously represented him in connection with another real estate loan, to
1 We refer to the Meers by their first names for ease of reference.
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assist him in obtaining the bank’s consent for a short sale of the residence. Lorenzetti had experience dealing with banks both as an accountant and as an employee of real estate developers. Ronald asked Lorenzetti to act as a business consultant, perform necessary accounting services, assess the likelihood of obtaining the bank’s agreement, prepare documentation to support the request, and act as Ronald’s representative with the bank, broker, and escrow company. On December 4, Ronald wrote an e-mail to a bank officer introducing Lorenzetti and authorizing him to conduct negotiations on Ronald’s behalf.
On December 8, Lorenzetti and Meer met and agreed to terms for Lorenzetti’s representation. Ronald agreed to pay a fixed fee of $15,000 and a 5 percent “success fee” based on any savings.
Lorenzetti proceeded to represent Ronald. In March 2009, the residence sold for $7 million via a short sale. The bank agreed to release all the debt owed, which totaled $10,865,642, and to accept $6,568,000 through escrow.
According to Ronald, the bank did not forgive or release the Meers’ debts. Lorenzetti, therefore, was not entitled to the “‘success fee’” but only the $15,000 fixed fee, which he claimed he paid.
According to Lorenzetti, however, the short sale resulted in a savings of $4,297,642 to the Meers, and Lorenzetti and Ronald “agreed that the success fee was earned.” Ronald agreed to pay, and Lorenzetti agreed to accept, $215,000 in satisfaction of the remaining obligations owed to him. Ronald agreed in writing to pay that sum through escrow. Eventually, however, to permit escrow to close, Lorenzetti agreed to accept the “$215,000 owed to him outside of escrow.” Following the closing, Ronald did not pay any part of this sum.
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B. Jill’s Bankruptcy Discharge In 2011, Jill filed for bankruptcy, primarily related to medical debts. Jill filed a list of creditors holding unsecured nonpriority claims and listed Lorenzetti’s corporation, Strategic Business Management Inc., with a claim for $25,000.2 Ronald asserts that both Lorenzetti and his corporation were sent notice of Jill’s bankruptcy filing and did not take any action in the bankruptcy proceedings. Lorenzetti does not dispute this.
On July 10, 2014, Jill received a chapter 7 discharge pursuant to 11 U.S.C. section 727. C. Lorenzetti’s 2013 Lawsuit In 2013, Lorenzetti filed his first complaint against the Meers for breach of contract, services rendered, account stated, fraud, and fraudulent conveyance. The parties reached an agreement under which Lorenzetti would dismiss this action without prejudice and refile it no less than one and no more than three years later. Lorenzetti agreed to assert only contract based claims, and the Meers agreed not to assert the statute of limitations as a defense. D. Lorenzetti’s 2015 Lawsuit In October 2015, Lorenzetti refiled his case against Ronald only, asserting the facts set forth above. He pleaded three causes of action, including breach of contract, services rendered, and account stated.
2 The fact that Jill’s listing of the amount owed was $25,000 is not
pertinent. Bankruptcy law focuses on notice to creditors and dischargeability, not the precise listing of the amount of a debt (which would have been at best unclear in 2011). (See, e.g., 11 U.S.C. § 523(a)(3) [debt is nondischargeable not listed or scheduled in time to allow the creditor to participate]; Licup v. Jefferson Avenue Temecula LLC (9th Cir. 2024) 95 F.4th 1234, 1238 [debt is “listed” if name and address of creditor is provided].) In any event, Lorenzetti has never contested the dischargeability of the debt.
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Lorenzetti sought general damages of $215,000 plus interest and special damages according to proof. Ronald filed a cross-complaint alleging unfair business practices and unjust enrichment, but dismissed it several months later.
On March 15, 2017, Lorenzetti and Ronald entered into a settlement agreement. The settlement agreement stated it constituted a “full settlement and compromise of this lawsuit and release and discharge of any and all claims and causes of action . . . arising out of the events” specified in the lawsuit. Ronald agreed to pay Lorenzetti $387,000, plus interest at the rate of 4.5 percent, in return for release and discharge of all claims. The agreement set forth a schedule for payments over time, and specified that upon Ronald’s failure to make any scheduled monthly payment within the allotted grace period, Lorenzetti would be entitled to entry of judgment for the full settlement amount of $387,000, less principal payments already made. The court was to retain jurisdiction to enforce the settlement pursuant to Code of Civil Procedure section 664.6. The case was dismissed pursuant to stipulation of the parties, with jurisdiction retained to enforce the agreement, on March 3, 2017.
On August 1, 2017, Lorenzetti sought, ex parte, entry of judgment following Ronald’s failure to pay. On the same date, the court entered judgment for $386,500, which was subsequently amended to include costs of $4,109.88, for a total judgment of $390,609.88.
There was not much activity in this case for several years.
Eventually some collection activity followed, including judgment debtor discovery (see Lorenzetti v. Meer (Mar. 6, 2026, G064834) [nonpub. opn.]), and a separate lawsuit filed by Lorenzetti in 2023 that we need not detail here.
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E. Ronald’s Motion to Stay Enforcement and the Court’s Order In February 2025, Ronald filed a motion to stay enforcement of the August 1, 2017 judgment. His motion argued that he and Jill had been married since 1988, and from the time of Jill’s 2014 bankruptcy discharge through the date of the motion, all of Ronald’s assets were community assets. Because Jill’s bankruptcy discharge included debt to Lorenzetti’s corporation, and both the corporation and Lorenzetti received proper notice, Lorenzetti was precluded from attempting to enforce or collect with respect to Ronald’s ownership in community property assets. While Lorenzetti could attempt to collect Ronald’s separate property, he had none.
Lorenzetti opposed. His key argument was that the judgment obtained following the settlement of the 2015 action was based on the 2017 settlement agreement. Lorenzetti contended that agreement was an entirely new and separate obligation that arose after the 2011 bankruptcy petition and 2014 discharge.
The court granted Ronald’s motion to stay enforcement of the judgment with respect to community property assets. Lorenzetti now appeals.
DISCUSSION
I.
STANDARD OF REVIEW
This appeal presents a pure question of law. The material facts relevant to that question of law are not disputed. Accordingly, our review is de novo. (Roberts v. United Health Care Services, Inc. (2016) 2 Cal.App.5th 132, 149.)
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II.
STATUTORY FRAMEWORK
“A chapter 7 bankruptcy petition creates an estate to satisfy creditors’ claims.” (In re Brace (2020) 9 Cal.5th 903, 913.) At the time of filing, that estate generally includes all separate and community property of the applicant. (Ibid.) Filing a petition for bankruptcy relief operates as a broad automatic stay, encompassing proceedings and collection attempts that impact the property of the bankruptcy estate or attempt to collect debts incurred prior to the petition. (11 U.S.C. § 362(a); Henderson v. White (In re Henderson) (Bankr. D.N.M. 2016) 560 B.R. 365, 369 (Henderson).)
Once the bankruptcy court enters a chapter 7 discharge, the discharge replaces the automatic stay. (Henderson, supra, 560 B.R. at p. 369.) The discharge injunction prohibits actions brought to collect any discharged debt. (Ibid.; see 11 U.S.C. § 524(a)(3).)
In community property states such as California, the spouse who is not named on the bankruptcy petition (the nondebtor spouse) benefits from the debtor spouse’s discharge of debts. The discharge prevents collection efforts against community property acquired after the petition was filed. “[C]ommunity claims are defined as claims that ‘arose before the commencement of the case concerning the debtor for which property of the kind specified in [§ 541(a)(2)] is liable.’” (Heilman v. Heilman (In re Heilman) (9th Cir. B.A.P. 2010) 430 B.R. 213, 217 (Heilman).) “Property specified in § 541(a)(2) includes all interests of the debtor and debtor’s spouse in community property liable for an allowable claim against the debtor and the debtor’s spouse.” (Id. at pp. 217–218.) This holds true even for claims brought solely against the nondebtor spouse. (Rooz v. Kimmel (In re Kimmel) (9th Cir. B.A.P. 2007) 378 B.R. 630, 632 (Kimmel).) There are several exceptions to
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this rule, but none of them are relevant in this case. (11 U.S.C. §§ 524(a)(3), 524(b).) Whether a particular debt is a community debt is determined by reference to state law. (Heilman, at p. 216.)
Notice is a key part of bankruptcy proceedings. After filing a bankruptcy petition, notice must be provided to potential claimants against the bankruptcy estate, including holders of community claims. (11 U.S.C. § 342.)
III.
THE TRIAL COURT CORRECTLY DETERMINED LORENZETTI CANNOT COLLECT COMMUNITY PROPERTY ASSETS ACQUIRED AFTER THE BANKRUPTCY DISCHARGE
Before we dive into Lorezetti’s arguments, we clarify what is not in dispute here. There is no dispute that the original debt incurred in 2008 is a community debt. Jill was named as a defendant in Lorenzetti’s 2013 lawsuit, which alleged he had entered into a written agreement with “the Meers” to renegotiate the debt on their home. “Plaintiff entered into an agreement with the Meers and fully performed his obligations under the agreement, but the Meers have failed and refused to pay plaintiff the amount they agreed to pay, and have attempted to avoid their obligations to plaintiff through fraud, including bankruptcy fraud and fraudulent conveyances.”
There is also no dispute that Lorenzetti received notice of Jill’s bankruptcy petition, but he did not file any documents in the bankruptcy proceeding.
Although Lorenzetti attempts to frame his argument in several different ways, his fundamental argument that the 2017 settlement agreement created a new debt entirely untethered to the original 2008 obligation lacks legal merit. Simply put, all of Ronald’s obligations to
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Lorenzetti arise out of the original 2008 obligation, and the unpaid judgment is therefore subject to the rules surrounding discharge of community debts.
Lorenzetti argues the 2017 settlement agreement was a “novation” that extinguished all prior claims and created entirely new obligations. He spends much time discussing state law on what creates a novation and what the intent of the parties might have been. “The question of when a debt arises under the bankruptcy code is governed by federal law.” (Siegel v. Federal Home Loan Mortgage Corp. (9th Cir. 1998) 143 F.3d 525, 532 (Siegel).) Accordingly, what matters here is how federal bankruptcy law characterizes this debt, and Lorenzetti’s arguments regarding a novation and the intent of the parties cite no federal cases on point.
The case law that is applicable here does not help Lorenzetti.
Siegel, supra, 143 F.4d. at page 533, held that an award of attorney fees incurred after the filing of a bankruptcy petition based on a cause of action that arose before the petition was not dischargeable.
In Siegel, supra, 143 F.3d 525, the debtor (Siegel) filed a bankruptcy petition after his mortgagee, Freddie Mac, foreclosed on a property Siegel owned and sued for a deficiency judgment. Freddie Mac filed proofs of claim to which Siegel did not object. In March 1994, Freddie Mac sought relief from the automatic stay so it could foreclose on a second property. (Id. at p. 528.)
In April 1994, Siegel filed a lawsuit in state court against Freddie Mac alleging breach of duties under the deeds of trust. (Siegel, supra, 143 F.3d at p. 528.) In June 1994, Siegel was granted a discharge. In October 1994, Freddie Mac removed the state court case to federal court and prevailed on a summary judgment motion. (Ibid.) Thereafter, Freddie Mac
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sought and was granted an attorney fee award for defending against Siegel’s claims. Siegel appealed. (Ibid.)
The Ninth Circuit held “the mere fact that Siegel obtained a bankruptcy discharge did not eliminate the provision. That is, it cannot be said that the whole contract merged into that judgment.” (Siegel, supra, 143 F.3d at p. 531.) A bankruptcy discharge “does not end a party’s obligation, but merely prevents one method of collection.” (Ibid.) Thus, the attorney fee provision in the contract was not extinguished. Rather, the Court held, “whether Freddie Mac’s claim for attorney’s fees was discharged in bankruptcy will depend on when the attorney’s fee debt arose.” (Id. at p. 532.)
The parties agreed that the contract was entered into prior to discharge, and Siegel’s acts that gave rise the attorney fee award occurred after the discharge. (Siegel, supra, 143 F.3d at p. 532.) The Court relied heavily on Siegel’s voluntary act of starting a new course of litigation to find that the attorney fee claim arose postdischarge. (Id. at pp. 532–533.)
“This is a case where the debtor, Siegel, had been freed from the untoward effects of contracts he had entered into. Freddie Mac could not pursue him further, nor could anyone else. He, however, chose to return to the fray and to use the contract as a weapon. It is perfectly just, and within the purposes of bankruptcy, to allow the same weapon to be used against him.” (Siegel, supra, 143 F.3d at p. 533.)
“Siegel’s decision to pursue a whole new course of litigation made him subject to the strictures of the attorney’s fee provision. In other words, while his bankruptcy did protect him from the results of his past acts, including attorney’s fees associated with those acts, it did not give him carte blanche to go out and commence new litigation about the contract without consequences.” (Siegel, supra, 143 F.3d at p. 534.) “Siegel thought that for
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him this was the best of all possible worlds. He thought that he could use bankruptcy to discharge all of his obligations under his contracts with Freddie Mac and still personally retain all of his rights arising out of those contracts.” (Ibid, italics added.) Based on this voluntary, postpetition action on Siegel’s part, the Court found the award of postpetition attorney fees was not discharged. (Ibid.)
Following Siegel, the Ninth Circuit decided Ybarra v. Boeing N.Am., Inc. (In re Ybarra) (9th Cir. 2005) 424 F.3d 1018 (Ybarra). In Ybarra, the debtor sued her employer in 1988 for employment-related claims. In 1991, she filed a chapter 11 bankruptcy petition. Significant litigation followed, and eventually, the debtor’s claim against the employer was scheduled as an exemption to what was, by then, a chapter 7 bankruptcy. The debtor was granted a discharge in May 1998. (Id. at pp. 1020–1021.)
The employment matter returned to state court, where ultimately, the employer prevailed on a summary judgment motion. (Ybarra, supra, 424 F.3d at pp. 1020–1021.) In 1999, the employer obtained a fees and costs judgment for over $450,000, and asked the bankruptcy court for permission to enforce it. (Id. at p. 1021; see Ybarra v. Boeing N.Am., Inc. (9th Cir. B.A.P. 2003) 295 B.R. 609, 612.) The bankruptcy court found the amount of fees and costs incurred after the bankruptcy petition was filed, $159,030.78, was collectible. (Ybarra, at p. 1021.)
The Ninth Circuit upheld the bankruptcy court’s findings.
(Ybarra, supra, 424 F.3d at p. 1022.) Finding the case was governed by discharge principles, the Court noted that “A Chapter 7 bankruptcy discharge releases the debtor from personal liability for her pre-bankruptcy debts.” (Ibid.) Specifically, 11 U.S.C. section 727 “‘discharges the debtor from all debts that arose before the date of the order for relief . . . .’” (Ibid.) “‘[D]ebt’”
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was defined as “‘liability on a claim’” and “‘[c]laim’” was broadly defined to include a “‘right to payment, whether or not such right is reduced to judgment, liquidated, unliquidated, fixed, contingent, matured, unmatured, disputed, undisputed, legal, equitable, secured, or unsecured.’” (Ibid.) “‘This “broadest possible definition” of “claim” is designed to ensure that “all legal obligations of the debtor, no matter how remote or contingent, will be able to be dealt with in the bankruptcy case.”’” (Ibid.)
The date of the debtor’s petition, the Court stated, was December 1991. (Ybarra, supra, 424 F.3d at p. 1022.) The employer argued its claim did not arise before that date and was therefore not discharged. (Ibid.)
The Court stated that “‘[a] claim arises, for purposes of discharge in bankruptcy, at the time of the events giving rise to the claim. . . .’” (Ybarra, supra, 424 F.3d at pp. 1022–1023.) The Ybarra court reached the same conclusion as the Siegel court did. “[W]e have held that post-petition attorney fee awards are not discharged where post-petition, the debtor voluntarily ‘pursued a whole new course of litigation,’ commenced litigation, or ‘returned to the fray’ voluntarily. [Citation.] We have also endorsed the notion that by voluntarily continuing to pursue litigation post-petition that had been initiated pre-petition, a debtor may be held personally liable for attorney fees and costs that result from that litigation.” (Ybarra, at p. 1024.)
Lorenzetti’s reliance on Ybarra, and by extension Siegel, is misplaced. This case is not about attorney fees that were incurred after the bankruptcy petition was filed. Nor did Ronald pursue new litigation or “‘return to the fray’” voluntarily. He was sued by Lorenzetti in both 2013 and 2015. The 2017 settlement agreement did not appear like a bolt of lightening from a clear blue sky. It was based on the allegations of the 2015 lawsuit, which alleged that in 2008, Ronald incurred debt to Lorenzetti. Indeed,
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everything in this case traces back to the original 2008 debt. Whether Lorenzetti frames his argument as one of “novation” or voluntary entry into a postdischarge debt, the result is the same. Under bankruptcy law, the debt arose in 2008, not 2017, and it was discharged during Jill’s bankruptcy proceeding.
Kimmel, supra, 378 B.R. 630, is more relevant to the instant case.
In that case, William B. Rooz sued the Kimmels, a married couple, in 1991. In 1993, the wife filed a chapter 7 petition, and she received a discharge in 1994. The 1991 case proceeded against the husband only, resulting in a judgment against him in May 1995. Two months later, the couple entered into a postnuptial agreement with the intent of transmuting the wife’s future wages from community property to separate property. (Id. at p. 633.)
Ten years later, in 2005, the husband filed his own chapter 7 petition when Rooz began attempts to collect on the debt. Rooz filed an adversary proceeding, seeking an order that the 1995 judgment was nondischargeable. Rooz, who asserted he found out about the postnuptial agreement during a meeting of creditors, amended his complaint to include the wife. The bankruptcy court found the 1995 judgment was dischargeable as to the husband and dismissed the case against the wife. (Kimmel, supra, 378 B.R. at p. 633.)
While Rooz’s appeal from the bankruptcy court’s order was pending, he filed a new state court action against the wife, seeking to recover a portion of her community property. He attacked the postnuptial agreement as a fraudulent transfer. The wife reopened her bankruptcy case, removed the state court case “to bankruptcy court, and moved for judgment on the pleadings.” (Kimmel, supra, 378 B.R. at p. 633.)
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The bankruptcy court granted the motion. The Court determined that any attempt to collect the 1995 judgment from the wife’s wages, regardless of whether they remained community property under the postnuptial agreement, was barred by the discharge injunction set forth in 11 U.S.C. section 524(a)(3). (Alternatively, the Court found the fraudulent transfer action was barred by the state law statute of limitations.) (Kimmel, supra, 378 B.R. at pp. 633–634.)
On appeal, the bankruptcy appellate panel found the 1995 judgment was a community claim that was discharged in the wife’s bankruptcy case. (Kimmel, supra, 378 B.R. at p. 640.) Rooz, the Court noted, conceded that the discharge provisions of 11 U.S.C. section 524 protected the wife from liability for the claims asserted in the 1991 litigation, but he contended the community property interest in her postdischarge wages was vulnerable to collection to satisfy the 1995 judgment. The Court rejected this contention completely. (Kimmel, at p. 634.)
First, the Court found that Rooz was a creditor holding a community claim in the wife’s bankruptcy. “[A] community claim, for bankruptcy purposes, is a prepetition claim for which the Kimmels’ community property was liable, whether or not such claim had proceeded to a judgment or otherwise was liquidated on the petition date.” (Kimmel, supra, 378 B.R. at p. 635.) This was particularly relevant in California, because under the Family Code, “community property is exposed to claims against an individual spouse. Cal. Fam. Code § 910(a).” (Ibid.)
Under 11 U.S.C. section 524(a)(3), however, the wife’s bankruptcy discharge “permanently enjoined enforcement of the 1995 Judgment against all future-acquired community property, including both her own and [the husband’s] interests in her wages.” (Kimmel, supra, 378 B.R. at p. 635.)
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Therefore, the nondebtor spouse’s liability survives the bankruptcy, but can only be enforced against separate property. (Id. at p. 636.) Ultimately, the Court found that even if the wife’s wages remained community property despite the postnuptial agreement, the husband’s interest in the community property was immune from any attempt to collect on the 1995 judgment. (Id. at p. 637.)
Rooz also argued that the wife’s postdischarge conduct by entering into the postnuptial agreement created a new debt. (Kimmel, supra, 378 B.R. at p. 638.) The Court rejected this argument. First, the Court held, the discharge was “absolute and, in light of the anti-waiver provisions of § 524(a), does not admit of an equitable exception that would permit it to be waived by postdischarge conduct.” (Ibid.) Second, 11 U.S.C. section 524(a)(3) prohibits any act “to collect or recover from” community property “that is acquired after commencement of the case, on account of any allowable community claim,” unless the claim has been excepted from discharge. “Thus, it was impossible for the community property ([the wife’s] future wages) that was transmuted into separate property to have been a source of recovery for Rooz.” (Kimmel, at p. 639.)
Kimmel not only has more in common with this case than Siegel or Ybarra, it also leaves a number of propositions very clear. The community property of a nondebtor spouse acquired after a bankruptcy discharge is uncollectable for any purpose. “[A]s one commentator has explained, ‘the Devil himself could effectively receive a discharge in bankruptcy if he were married to Snow White.’” (Kimmel, supra, 378 B.R. at p. 637.) The only question here is when the debt arose, and as we have noted, the entire debt can be unambiguously traced back to the original 2008 debt the Meers incurred to Lorenzetti.
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When a bankruptcy proceeding occurs, creditors must be diligent.
(Kimmel, supra, 378 B.R. at p. 637.) Lorenzetti had ample opportunity to seek redress during Jill’s bankruptcy proceeding. After he received notice, he could have filed a claim against the bankruptcy estate, a nondischargeability action, or an objection to discharge. (Ibid.) He did none of these. Based on fundamental principles and the strong protections that bankruptcy law affords, however, he cannot now seek to collect what was a prepetition community debt.
IV.
LORENZETTI MAY ATTEMPT TO COLLECT THE DEBT FROM RONALD’S SEPARATE PROPERTY
Lorenzetti also argues that he “retains the right to collect from any separate property [Ronald] may acquire and from [Ronald]’s interest in community property.” He is half right. As we have discussed, he cannot collect from community property acquired after the date of the petition. (11 U.S.C. 524 (a)(3).) He may attempt to collect from Ronald’s separate property, if any. The court’s order stated as much: “The motion to stay enforcement of the judgment with respect to community property assets is GRANTED. To the extent that the judgment may be enforced, Lorenzetti may only seek enforcement against [Ronald]’s separate property assets.” Judgments, as the saying goes, last a long time. In California, they can last for 20 years. (Code Civ. Proc. §§ 683.020, 683.120.) Should Ronald’s circumstances change, the posture of this case may also change significantly.
Lorenzetti also contends “normal collection procedures should be permitted to determine what assets, if any, are available for satisfaction.” We have no order before us that limits what collection procedures may or may
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not be used, and accordingly, it would be inappropriate for us to opine on this subject.
Lorenzetti argues that Ronald’s arguments create “perverse incentives” for bad behavior by nondebtor spouses and “discourage settlements.” We cannot help with these policy arguments. Bankruptcy law, as Lorenzetti surely knows, is federal law. His only redress for these supposed ills lies with federal legislators, not this court.
DISPOSITION
The postjudgment order is affirmed. Ronald is entitled to his costs on this appeal.
MOORE, J.
WE CONCUR:
MOTOIKE, P. J.
SERVINO, J.