In Langston v. Dallas Commodity Company, No. 24-10883 (5th Cir. Nov. 17, 2025), the U.S. Court of Appeals for the Fifth Circuit addressed a recurring challenge in consumer bankruptcy practice: what happens when a trustee fails to properly continue a Section 341 meeting of creditors under Federal Rule of Bankruptcy Procedure 2003(e)? While the court affirmed that such procedural failures do not automatically trigger a bright-line rule concluding the meeting, it established important precedent distinguishing between cases where another meeting is actually held versus cases where no further meeting occurs. Most significantly for practitioners, the decision underscores how easily debtors can waive the protections of the 30-day deadline to object to exemptions under Rule 4003(b)(1)—and provides a roadmap for avoiding such waivers.
[Read more…] about 5th Circuit Holds That The 30-Day Window To Object to Exemptions in Rule 4003(b)(1) Can Be WaivedBankruptcy Court Denies USA’s Blanket Request for Tolling of Deadlines During Lapse of Appropriations
In an unpublished opinion, the Bankruptcy Court for the Northern District of Ohio recently denied a motion from the United States Attorney’s Office “requesting a tolling of all deadlines applicable to the United States, its agencies, or its employees, including, without limitation a tolling of all bar dates for the filing of proofs of claim and request for the payment of administrative expenses with respect to the United States and its agencies from December 22, 2018 through January 28, 2019 (the “Appropriations Lapse”).”
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