Wayne Grantham and Lanae Grantham

CourtUnited States Bankruptcy Court, C.D. California
DecidedMay 7, 2020
Docket6:20-bk-11740
StatusUnknown

This text of Wayne Grantham and Lanae Grantham (Wayne Grantham and Lanae Grantham) is published on Counsel Stack Legal Research, covering United States Bankruptcy Court, C.D. California primary law. Counsel Stack provides free access to over 12 million legal documents including statutes, case law, regulations, and constitutions.

Bluebook
Wayne Grantham and Lanae Grantham, (Cal. 2020).

Opinion

3 FILED & ENTERED

4 MAY 07 2020 5

6 CLERK U.S. BANKRUPTCY COURT Central District of California BY g o o c h DEPUTY CLERK 7

8 UNITED STATES BANKRUPTCY COURT

9 CENTRAL DISTRICT OF CALIFORNIA

10 RIVERSIDE DIVISION

12 In re: Case No.: 6:20-bk-11740-WJ 13 WAYNE GRANTHAM and CHAPTER 7 14 LANAE GRANTHAM,

15 Debtors. MEMORANDUM OF DECISION REGARDING DISMISSAL OF THE CASE 16 FOR FAILURE TO OBTAIN CREDIT COUNSELING 17

18 19

20 21 22 23 24 25 26 27 28 2 The debtors, Wayne and Lanae Grantham (“Debtors”), filed this chapter 7 case and one 3 of them (Lanae Grantham) did not obtain credit counseling prior to filing the case. As a result, 4 hearings are currently scheduled for May 13, 2020 at 10:30 a.m. regarding (1) the motion of the 5 debtors to excuse the requirement to obtain credit counseling as to Mrs. Grantham [docket #10] 6 (“Excusal Motion”) and (2) the order of this Court to show cause regarding why the case should 7 not be dismissed for failure to obtain credit counseling (“OSC”). Neither of the debtors has filed 8 opposition to the OSC and the deadline to do so has passed. Therefore, having reviewed the 9 case, the Excusal Motion and the OSC, the Court hereby finds that no oral argument is necessary 10 and, pursuant to Rule 9013-1(j)(3) of the Local Bankruptcy Rules, the Court hereby takes off 11 calendar the hearing and waives appearances. No hearings shall occur. 12 For the following reasons, the Court shall dismiss the case as to Lanae Grantham only. 13 14 II. JURISDICTION 15 The bankruptcy court has jurisdiction over this contested matter pursuant to 16 28 U.S.C. §§ 157(b) and 1334(b). The Excusal Motion and the OSC are core proceedings 17 pursuant to 28 U.S.C. §§ 157(b)(2)(A) and (L). Venue is appropriate in this Court. 18 28 U.S.C. § 1409(a). 19 With respect to the OSC, case authority provides that a bankruptcy court can dismiss a 20 bankruptcy case sua sponte when a debtor is ineligible for bankruptcy relief due to a failure to 21 obtain pre-petition counseling. Gibson v. Dockery (In re Gibson), 2011 Bankr. LEXIS 5084, *14 22 (9th Cir. BAP 2011) (finding that a bankruptcy court can dismiss a case sua sponte when a debtor 23 fails to obtain pre-petition counseling and stating that the “bankruptcy court’s sua sponte order 24 dismissing Debtor’s bankruptcy case without prior notice or an opportunity to be heard was 25 appropriate.”). The Court entered the OSC on April 3, 2020 and set a hearing regarding the 26 matter for May 13, 2020. The OSC set a deadline of April 29, 2020 for the Debtors to file and 27 serve any opposition to the OSC. No opposition was filed and the deadline has passed. 28 2 A. Applicable Legal Standard. 3 When the Debtors commenced this bankruptcy case, Mr. Grantham filed a certificate of 4 credit counseling but Mrs. Grantham did not. Instead, the Debtors filed the Excusal Motion 5 seeking an order excusing Mrs. Grantham from obtaining credit counseling.1 However, 6 applicable law does not provide for an exemption under the circumstances in this case. 7 Section 109(h)(1) of the Bankruptcy Code provides that no individual may file a 8 bankruptcy case unless that individual has received credit counseling from an approved agency 9 during the 180-day period prior to filing the petition. The credit counseling may be conducted in 10 person, by telephone or internet. 11 U.S.C. § 109(h)(1). Congress wants debtors to receive credit 11 counseling as a condition for bankruptcy relief “so that they will make an informed choice about 12 bankruptcy, its alternatives, and consequences.” H.R. Rep. No. 109-31 at 2 (2005), U.S. Code 13 Cong. & Admin. News 2005. With respect to the latter, there are many significant consequences 14 1 In addition to asking for a waiver of the credit counseling requirement for Mrs. Grantham, the Excusal 15 Motion also appears to ask for some other form of relief. The caption of the Excusal Motion also includes the following phrase: “Motion to Extend Filing Date of 3/16/2020 of the Pre-Filing Credit Counseling Certificate.” 16 Similar language appears in section II of the Excusal Motion from page 2, line 19 of the motion to page 3, line 2. The language in both locations is somewhat cryptic, but the Court may be able to interpolate the request as follows. 17 When Mrs. Grantham did not file a certificate of credit counseling on the petition date (but Mr. Grantham 18 did), the clerk of the court issued a deficiency notice which gave her until March 16, 2020 to file the credit counseling certificate. See docket #5. It seems most likely that the cryptic language in the Excusal Motion is designed to extend 19 the March 16th deadline until the hearing regarding the Excusal Motion. The language on page 2, lines 22-24 seem to indicate this is the relief requested. If this is the additional relief requested, then it is no longer necessary because the 20 case was not dismissed on March 16th and will not be dismissed until entry of the order that accompanies this memorandum of decision. As a result, if this is the nature of the relief requested, it is moot. 21 If, on the other hand, the cryptic language requests an opportunity for Mrs. Grantham to obtain credit 22 counseling post-petition and then file a certificate post-petition, that request is denied. Courts have held that if debtors obtain the counseling post-petition but not pre-petition, the cases must be dismissed. See, e.g., Gibson v. Dockery 23 (In re Gibson), 2011 Bankr. LEXIS 5084, *14 (9th Cir. BAP 2011) (“Debtor did not obtain credit counseling during the 180 days prior to filing her petition. While she completed counseling a few days later, she did not request nor 24 secure bankruptcy court approval to do so post-petition due to any exigent circumstances, nor did she seek an exemption from the counseling requirement under one of the other § 109(h) exceptions. Because Debtor did not 25 comply with the § 109(h) pre-bankruptcy credit counseling requirement, Congress has decreed that she was not eligible to be a chapter 13 debtor, and dismissal of her case by the bankruptcy court was appropriate.”); In re Ramey, 558 B.R. 160, 163 (6th Cir. BAP 2016) (affirming dismissal of a chapter 13 case in which a debtor took the credit 26 counseling post-petition and stating that the Bankruptcy Code specifically requires “all individual debtors to complete a pre-petition credit briefing.”); Echeverry v. Weiner (In re Echeverry), 720 Fed. Appx. 598, n.1 (11th Cir. 2018) 27 (affirming dismissal of a chapter 13 case in which a debtor, among other things, took the credit counseling post-petition and stating that in failing to take the counseling pre-petition the debtor “failed to comply with the Bankruptcy Code’s 28 plain language requirement that a debtor complete the counseling prior to the filing of the case.”). 2 Given the sometimes harsh results of filing for bankruptcy, Congress not only requires pre- 3 petition counseling but also requires financial management training after filing for bankruptcy so 4 that the debtor “can avoid future financial difficulties.” Id. at 18. These requirements, which 5 Congress has deemed to be critical, are intended to ensure that debtors have at least a modicum 6 of information from which they can make an informed decision regarding filing for bankruptcy 7 relief. As one bankruptcy court has stated:

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