[CLBS] In re Flores

[Alexandra Caval]

Everyone:

The 9th Circuit just issued its en banc decision in Flores which overturns Kagenveama and ends the split between the 9th Circuit and the 6th, 8th and 11th Circuits. The applicable commitment period is now a temporal requirement. Under Flores, above-median debtors with negative projected disposable income on line 59 of the 22C will be required to propose a 60-month plan; they can no longer propose a plan term that is less than 60 months.

Sincerely,

Alexandra O. Caval
Staff Attorney
Office of Kathleen A. McCallister
Chapter 13 Trustee
P.O. Box 1150
Meridian, ID 83680
T: (208) 922-5100
F: (208) 922-5599
alex at kam13trustee.com<mailto:alex at kam13trustee.com>

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