Renasant Bank v. Joseph Sanchez

• Court: Court of Appeals for the Eleventh Circuit
• Decided: December 31, 2025
• Docket: 25-11160
• Status: Unpublished

Opinion

USCA11 Case: 25-11160 Document: 24-1 Date Filed: 12/31/2025 Page: 1 of 6

NOT FOR PUBLICATION

In the United States Court of Appeals For the Eleventh Circuit ____________________ No. 25-11160 Non-Argument Calendar ____________________

In re: JOSEPH SANCHEZ, Debtor. ___________________________________ RENASANT BANK, Plaintiff-Appellant, versus

JOSEPH SANCHEZ, Defendant-Appellee. ____________________ Appeal from the United States District Court for the Northern District of Alabama D.C. Docket No. 5:24-cv-01746-RDP ____________________

Before JILL PRYOR, LUCK, and BRASHER, Circuit Judges. PER CURIAM: USCA11 Case: 25-11160 Document: 24-1 Date Filed: 12/31/2025 Page: 2 of 6

2 Opinion of the Court 25-11160

After Joseph Sanchez’s bankruptcy proceedings were closed, Renasant Bank asked the bankruptcy court to reopen them. Re- nasant argued that Sanchez was taking actions in state court that shirked his obligations stemming from his bankruptcy petition. The bankruptcy court declined to reopen the proceedings, con- cluding that Renasant was free to pursue its claims in the pending state court ejectment case. Renasant appealed to the district court, but the district court affirmed because the bankruptcy court had not abused its discretion. After careful review, we also affirm. FACTUAL BACKGROUND AND PROCEDURAL HISTORY Sanchez failed to make payments on his mortgage held by Renasant, so Renasant sought to foreclose on the home secured by the mortgage. But the day before the foreclosure sale, Sanchez filed a chapter 13 bankruptcy petition. That first petition was dis- missed on procedural grounds, which allowed Renasant to re- schedule the foreclosure sale. Yet, the day before the rescheduled sale, Sanchez filed a sec- ond chapter 13 bankruptcy petition. Renasant moved for relief from the bankruptcy court’s automatic stay, which the bankruptcy court granted. With relief from the stay, Renasant, again, noticed Sanchez’s home for a foreclosure sale. But on the day of the sched- uled sale, Sanchez converted his chapter 13 bankruptcy into a chap- ter 7 bankruptcy, which, once again, caused a delay. As part of the conversion, three things happened. First, Sanchez filed a statement declaring his intent to retain the home and enter into a reaffirmation agreement with Renasant. Second, USCA11 Case: 25-11160 Document: 24-1 Date Filed: 12/31/2025 Page: 3 of 6

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Renasant secured relief from the automatic stay to foreclose on Sanchez’s home. And third, the bankruptcy court discharged Sanchez’s debts and closed the case. After the foreclosure sale, Renasant sought to eject Sanchez from the home in state court. In response, Sanchez filed counter- claims against the bank for breaching the loan agreement and wrongfully foreclosing on the home. Renasant then went back to the bankruptcy court to reopen the chapter 7 case, arguing that Sanchez’s positions in state court ran afoul of his obligations under the bankruptcy code. The bank- ruptcy court denied Renasant’s motion, concluding that Renasant chose to petition to lift the automatic stay to pursue its rights in state court and that forum was available to vindicate the bank’s rights. Renasant appealed the bankruptcy court’s decision to the district court, arguing the bankruptcy court was required to reopen the proceedings. The district court affirmed, explaining that the bankruptcy court had not abused its discretion in refusing to reo- pen because Renasant could pursue its claims in state court. Re- nasant now appeals to us. STANDARD OF REVIEW We sit as a “second court of review” in a bankruptcy appeal, applying the same standard of review the district court applied. In re Fundamental Long Term Care, Inc., 81 F.4th 1264, 1319 (11th Cir. 2023). In considering a motion to reopen bankruptcy proceedings, “the bankruptcy court retains broad discretion to reopen.” Slater v. USCA11 Case: 25-11160 Document: 24-1 Date Filed: 12/31/2025 Page: 4 of 6

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United States Steel Corp., 871 F.3d 1174, 1186–87 (11th Cir. 2017) (en banc). Thus, we review for abuse of discretion a decision to reopen bankruptcy proceedings. In re Haker, 411 F.2d 568, 569 (5th Cir. 1969). DISCUSSION Renasant argues that the bankruptcy court abused its discre- tion when it denied its motion to reopen the proceedings. We dis- agree. Section 350 of the bankruptcy code allows for “[a] case” to “be reopened in the court in which such case was closed to admin- ister assets, to accord relief to the debtor, or for other cause.” 11 U.S.C. § 350(b). Section 350(b)’s use of the phrases “may be reo- pened” and “for other cause” confirms that the statute affords the bankruptcy court “broad discretion.” See Slater, 871 F.3d at 1186. “[T]he abuse of discretion standard allows a range of choice,” In re Rasbury, 24 F.3d 159, 168 (11th Cir. 1994) (citation modified), and “[a]n abuse of discretion occurs if the judge fails to apply the proper legal standard,” In re Fundamental, 81 F.4th at 1219–20 (quoting Elec- tro-Wire Prods., Inc. v. Sirote & Permutt, P.C., 40 F.3d 356, 359 (11th Cir. 1994)). The bankruptcy court did not abuse its discretion because it properly identified section 350(b) as the governing legal standard and made a decision that was within the range of acceptable choices. Renasant had to show that the bankruptcy court acted outside that range and made “a clear error in judgment,” Rasbury, 24 F.3d at 168, but, at best, its arguments demonstrate that the USCA11 Case: 25-11160 Document: 24-1 Date Filed: 12/31/2025 Page: 5 of 6

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bankruptcy court could have chosen to reopen the proceedings, 1 not that it had to. The bankruptcy court exercised its discretion as it did be- cause Renasant chose to petition to lift the automatic stay to pursue its rights in state court and that forum continued to be available to vindicate the bank’s rights. Renasant has pointed to no binding au- thority supporting its argument that the bankruptcy court’s deci- sion to consider these factors was impermissible, arguing instead that the state court does not provide it with an adequate remedy. When Sanchez failed to reaffirm his mortgage as he had pledged on his statement of intent, Renasant moved for relief from the automatic stay, which the bankruptcy court granted. Renasant chose not to seek an order related to Sanchez’s statement of intent while the bankruptcy case was pending. Later, when the bank- ruptcy court addressed Renasant’s motion to reopen the chapter 7 case, it acted well within its discretion when it determined that Re- nasant’s choice to pursue relief from the automatic stay made state court the appropriate forum to seek relief. Renasant counters by citing nonbinding cases in which bankruptcy courts have exercised their discretion to reopen cases. See, e.g., In re Woide, 730 Fed. App’x. 731 (11th Cir. 2018)

1 Renasant also argues that the bankruptcy court needed to reopen the pro- ceedings because the bankruptcy estate was not fully administered and be- cause Sanchez committed fraud. But it never raised these issues in front of the bankruptcy court, and we decline to consider them for the first time on appeal. See Access Now, Inc. v. Sw. Airlines Co., 385 F.3d 1324, 1331–32 (11th Cir. 2004). USCA11 Case: 25-11160 Document: 24-1 Date Filed: 12/31/2025 Page: 6 of 6

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(unpublished); In re Perez, 638 B.R. 248 (Bankr. S.D. Fla. 2022). But Renasant fails to appreciate what constitutes an abuse of discretion, a standard of review that can require affirming a lower court’s de- cision even if we would have decided the issue the other way. See Rasbury, 24 F.3d at 168. In other words, at most, Renasant has shown that the bankruptcy court could have reopened the pro- ceedings, not that it abused its discretion when it refused to. Renasant next counters that the state court ejectment case does not provide it with an adequate remedy, arguing that Ala- bama’s treatment of motions to dismiss and jury trials will slow down the process of adjudicating Sanchez’s claims. But that argu- ment fails too. While there may be disadvantages to litigating its claims in state court, Renasant has not shown that a remedy is un- available to it there. Because the bankruptcy court did not abuse its discretion in denying the motion to reopen, we, like the district court, must af- firm that decision. AFFIRMED.