Trustees in two chapter 7 cases objected to debtors' exemption claims in prepetition wages. The court held that the Utah Exemptions Act, Utah Code Ann. §78-23-1 through 78-23-15, prohibits the use of 11 U.S.C. § 522(d) exemptions by Utah debtors. However, § 78-23-15 does not prohibit Utah debtors' use of exemptions that are provided by Utah laws outside of the Exemptions Act, of which there are many. Moreover, pursuant to 11 U.S.C. § 522(b)(2)(A), Utah debtors may also claim federal exemptions that are provided by federal statutes other than § 522(d). Together, Utah Code Ann. § 70B-5-105 and Utah R. Civ. P. 64D exempt Utah debtors' wages in bankruptcy, even though they are technically garnishment laws and do not specifically state that they are applicable in bankruptcy. Non-bankruptcy exemptions need not specify that they apply in bankruptcy cases in order to do so.

In an action to determine dischargeability under 11 U.S.C. § 523(a), the court held as follows: (1) a non-dischargeable judgment entered by a bankruptcy court is a judgment entered "for and on behalf of the United States District Courts" in a "district court civil proceeding," under In re Color Craft Press, Ltd., 27 B.R. 962 (D. Utah 1983), so that postpetition interest on the judgment is governed by 28 U.S.C. § 1961; (2) pre-judgment interest in dischargeability actions is awardable at the contract rate if there is a contract, or at the legal rate if there is not; (3) pursuant to In re Cowart, Civ. No. 81-0929J (D. Utah Sept. 20, 1982) (Jenkins, J.), punitive damages are not awardable in non-dischargeability actions, notwithstanding contrary case law from other jurisdictions; (4) a state court's default judgment that is based on the operative facts underlying their dischargeability action in bankruptcy has no res judicata effect; and (5) although collateral estoppel is a viable doctrine in non-dischargeability actions, the bankruptcy court will not give collateral estoppel effect to a default judgment.

The court considered four chapter 13 cases in which creditors had failed to file timely proofs of claim under Bankruptcy Procedure Rule 13-302(e). The court first held that Rule 13-302(e) was not inconsistent with the new Bankruptcy Code and, therefore, that it continued to apply in Bankruptcy Code cases. Under Rule 13-302(e), a secured creditor that failed to file a proof of claim before the conclusion of the meeting of creditors will be treated as unsecured. An unsecured creditor's failure to file a proof of claim within six months of the creditors meeting will receive no disbursements under the plan. The new Code, however, allows the debtor or trustee to file a proof of claim on behalf of a creditor that did not timely file one, and there is no time limit placed on that action. Therefore, where debtors had filed such proofs on behalf of their creditors, the claims were preserved. The court further held that a provision for payment of a creditor's claim under a debtor's plan amounts to a consent to the claim by the debtor, which has the same effect as debtor filing a proof of claim on creditor's behalf. With respect to untimely proofs of claim filed by the IRS, none of which was included in debtors' plans, the court concluded that taxes become "payable" on the date the returns are originally due, not when the returns were filed, nor when the tax was assessed. Therefore, all but one of the IRS claims were barred by Rule 13-302(e), but a claim that had become payable postpetition was allowed by 11 U.S.C. § 1305(a)(1).

In a removed case based on state law, defendant's jury trial demand was denied by the court as untimely under interim Bankruptcy Rule 7004(g) and Local Rule 11(a), and defendant was deemed to have waived trial by jury. Although Rule 11(a) allows such waivers to be set aside for good cause, an oversight by counsel was not good cause. Defendant's motion to transfer the case from the bankruptcy court to the district court, which had been improperly filed with the bankruptcy court, was referred to the district court for disposition.