Taylor v. Taylor (In re Taylor)

271 B.R. 157, 45 Collier Bankr. Cas. 2d 1378, 2001 Bankr. LEXIS 121, 2001 WL 1663309
CourtUnited States Bankruptcy Court, W.D. Arkansas
DecidedJanuary 2, 2001
DocketNo. 00-70345
StatusPublished
Cited by1 cases

This text of 271 B.R. 157 (Taylor v. Taylor (In re Taylor)) is published on Counsel Stack Legal Research, covering United States Bankruptcy Court, W.D. Arkansas primary law. Counsel Stack provides free access to over 12 million legal documents including statutes, case law, regulations, and constitutions.

Bluebook
Taylor v. Taylor (In re Taylor), 271 B.R. 157, 45 Collier Bankr. Cas. 2d 1378, 2001 Bankr. LEXIS 121, 2001 WL 1663309 (Ark. 2001).

Opinion

ORDER AVOIDING JUDICIAL LIEN

ROBERT F. FUSSELL, Bankruptcy Judge.

Pending before the Court is the debtor’s Motion to Avoid Judicial Lien, filed by the debtor, Janet Taylor, on June 6, 2000. The debtor attempts to avoid the lien held by the respondents, George and Inis Taylor, in the debtor’s real property pursuant to 11 U.S.C. § 522(f)(1)(A).1 George and Inis Taylor argue that their lien is an equitable lien and, accordingly, can not be [159]*159avoided under § 522(f)(1). A hearing on this matter was held on October 16, 2000, at which time the Court took the matter under advisement and allowed both parties to file post-hearing briefs and a joint stipulation of facts. For the reasons stated below, the lien may be avoided.

This Court has jurisdiction over this matter pursuant to 28 U.S.C. § 1334 and 28 U.S.C. § 157, and it is a core proceeding pursuant to 28 U.S.C. § 157(b)(2)(E). The following findings are in accordance with Federal Rule of Bankruptcy Procedure 7052.

The facts in this case are fairly simple and not in dispute by the parties. The debtor, Janet Taylor, is the ex-wife of Virgil Taylor, who is the son of the respondents, George and Inis Taylor. During their marriage, George and Inis Taylor provided $14,400.00 to the debtor and Virgil Taylor. The money was used to assist with the construction of a house located on real property in Sebastian County, Arkansas, which was owned by the debtor and Virgil Taylor. This property is the subject matter of this action. Virgil Taylor, George Taylor, and Inis Taylor executed a document dated April 10, 1990, and signed February 17, 1991, that appears to be a promissory note in the amount of $14,700.00. Under the terms of that note, Virgil Taylor agreed to repay George and Inis Taylor at the rate of $50.00 per month until paid in full. Janet Taylor did not sign the document, and, in fact, does not appear on the document at all. On July 11, 1994, the debtor and Virgil Taylor executed a note and mortgage in favor of City National Bank of Fort Smith in relation to the real property.

The debtor and Virgil Taylor were divorced on March 25, 1997. Under the agreed upon terms of the divorce decree, Virgil Taylor quitclaimed his interest in the real property to the debtor, and the debtor was to “assume the indebtedness on the homeplace .... ” After the divorce, the debtor made no payments to George and Inis Taylor with respect to the promissory note executed by Virgil Taylor. George and Inis Taylor filed a Foreclosure Complaint against the debtor and Virgil Taylor, which was heard in the Chancery Court of Sebastian County on March 1, 2000. The chancellor found that the debtor “was aware of the indebtedness [to George and Inis Taylor] and agreed to be responsible for the indebtedness .... ” The chancellor then ordered that judgment be entered in favor of George and Inis Taylor and against Virgil Taylor and Janet Taylor in the amount of $14,400.00, without interest. The chancellor also ordered that if the judgment was not paid within 30 days, the clerk of the court, acting as Commissioner in Chancery, should sell the property “pursuant to this Order and the laws of the State of Arkansas that pertain to the sell [sic] of real property under Foreclosure Decree.”

The debtor filed her chapter 7 petition on March 28, 2000. Under 11 U.S.C. § 522(b),2 and Ark.Code Ann. § 16-66-217 [160]*160(Supp.1999),3 a debtor may exempt from property of the estate either (1) certain property listed in § 522(d) of the bankruptcy code, or (2) property that is exempt under applicable non-bankruptcy federal law and the state and local laws of the place where the debtor has been domiciled for the longest portion of the 180 days preceding the bankruptcy filing. The debtor claimed the real property exempt under the laws of the State of Arkansas as her homestead. By electing the exemptions provided by state law, the debtor is entitled to exempt up to 80 acres of rural property without regard to value.4 George and Inis Taylor filed an objection to exemption on September 18, 2000, but withdrew their objection on October 16, 2000. There were no other objections filed.

Under applicable bankruptcy law, a debtor may avoid the fixing of a judicial lien on the debtor’s property to the extent that it impairs an exemption to which she is otherwise entitled. 11 U.S.C. § 522(f)(1)(A). However, in order to avoid a lien, three conditions must be met: (1) the hen must be a judicial lien; (2) the lien must fix on an interest of the debtor in property; and (3) the lien must impair an exemption of the debtor. See Cloud v. Cloud (In re Cloud), 215 B.R. 870, 872 (Bankr.E.D.Ark.1997).

A judicial lien is defined in the bankruptcy code as a “lien obtained by judgment, levy, sequestration, or other legal or equitable process or proceeding.” 11 U.S.C. § 101(36). A hen is defined as a “charge against or interest in property to secure payment of a debt or performance of an obligation.” 11 U.S.C. § 101(37). By way of explanation, “a judicial lien is an interest which encumbers a specific piece of property granted to a judgment creditor who was previously free to attach any property of the debtor’s to satisfy his interest but who did not have an interest in a specific piece of property before the occurrence of some judicial action.” Boyd v. Robinson (In re Boyd), 31 B.R. 591, 594 (D.Minn.1983). On the other hand, an equitable lien recognizes a pre-existing property right that would predate any judgment granted that enforces or recognizes that right. See Cloud, 215 B.R. at 873.

George and Inis Taylor had no interest in the subject real property prior to [161]*161the Chancery Court’s entry of judgment against Virgil Taylor and the debtor. The debtor did not sign the promissory note given to George and Inis Taylor, and George and Inis Taylor did not have a security interest in the property. City National Bank of Fort Smith had a mortgage on the property, George and Inis Taylor did not. Even if the debtor agreed to be responsible for the debt (and it appears that she did), the debt was not tied to the real property in any manner that would give rise to a security interest in the property. George and Inis Taylors’ interest in the subject property was first recognized when the chancellor granted them a judgment against the debtor. Under Arkansas law, the judgment granted by the chancellor became a lien on the real property owned by the debtor when the order was filed with the clerk of the court.5

The respondents referred the Court to In re Cloud, 215 B.R. 870 (Bankr.E.D.Ark.1997), in their post-hearing brief. In re Cloud

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Cite This Page — Counsel Stack

Bluebook (online)
271 B.R. 157, 45 Collier Bankr. Cas. 2d 1378, 2001 Bankr. LEXIS 121, 2001 WL 1663309, Counsel Stack Legal Research, https://law.counselstack.com/opinion/taylor-v-taylor-in-re-taylor-arwb-2001.