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Ninth Circuit Allows Emotional Distress Damages for Violation of Section 524(i)

In an unpublished memorandum disposition, the Ninth Circuit affirmed a Bankruptcy Appellate Panel decision reviving Chapter 13 debtors’ claim that their mortgage creditors violated the discharge injunction by failing to properly credit payments made under their confirmed plan. In Valdellon v. PHH Mortgage Corp., No. 25-538 (9th Cir. Apr. 20, 2026), the court held that […]

• Cure
• Discharge Injunction
• Finality of Discharge
• Jurisdiction
• Sanctions

Tags: 3002.1, 524(i), bankruptcy, Taggart

April 28, 2026

9th Circuit BAP Opinion

9th Circuit opinion – Valdellon

Valdellon v. PHH Mortg. Corp. (In re Valdellon) – BAP opinion

April 27, 2026

Valdellon v Wells Fargo – Appellee’s brief – 9th Circuit

Valdellon v Wells Fargo – Appellant’s Reply brief – 9th Circuit

Valdellon v Wells Fargo – Appellant’s brief – 9th Circuit

Valdellon v Wells Fargo – Amicus Brief – 9th Circuit

Fourth Circuit Rejects Equitable Mootness in Chapter 13 Plan Confirmation Appeal

In a published opinion, the Fourth Circuit held that a district court erred in dismissing a Chapter 13 debtor’s appeal as equitably moot merely because a later plan had been confirmed and payments had begun. In Cook v. Chapter 13 Trustee, No. 25-1048 (4th Cir. Apr. 13, 2026), the court emphasized that equitable mootness is […]

• appealability
• confirmation

Tags: bankruptcy, chapter 13, equitable mootness

Cook Appellee-Trustee Brief