Law360, New York ( October 24, 2014, 11:29 AM EDT) -- This past June, the United States Court of Appeals for the Eleventh Circuit, in Wells Fargo Bank NA v. Scantling, 754 F.3d 1323 (11th Cir. 2014), held that a "Chapter 20" debtor could strip off valueless junior liens on her principal residence despite being ineligible for a discharge in her Chapter 13 bankruptcy case. A "Chapter 20" debtor is a person who previously obtained a discharge of debt in a Chapter 7 case and then filed a Chapter 13 case to restructure certain debt not satisfied in the Chapter 7 case, like home mortgage debt....
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