Debtor filed an adversary action asserting that defendant had failed to make royalty payments required under the parties' lease, and seeking to terminate the parties' contract. Debtor and the purchaser of oil from defendant agreed that purchaser would thereafter pay royalties directly to debtor, leaving only the lease termination to be determined by the court. However, the court exercised its discretion to abstain from hearing the lease dispute, concluding that the state had a comprehensive regulatory system in place to deal with oil and gas production and drilling activity that was uniquely situated to fashion an appropriate remedy. Therefore, the court considered debtor's claim to be premature, as state administrative remedies had not been exhausted.

Plaintiffs needed funding for a condominium development project, and went to debtor, in his capacity as president of an escrow company, to obtain "offshore" funding. Ultimately, the expected funding did not come through, and plaintiffs lost their commitment fee, which debtor had paid on their behalf to the lender. Plaintiffs filed an adversary complaint in debtor's bankruptcy, alleging non-dischargeability under 11 U.S.C. § 523(a)(2)(A) and (a)(4). With respect to plaintiffs' fraud claim, the court held that no fraudulent intent had been shown. The court then considered the fiduciary defalcation claims, ruling that only one of plaintiffs' two fiduciary claims involved fiduciary duty, which was debtor's alleged mishandling of plaintiffs' funds. The court concluded that debtor's promise to pledge accounts receivable to cover plaintiffs' funds if their loan was not funded was not fiduciary in nature, despite it being a duty that was imposed by the same contract as debtor's fiduciary duty, since the claim did not involve placement of property into debtor's custody. Rather, promises made by debtor regarding his or his company's money were contractual only. Finally, the court determined that plaintiffs had failed to show a defalcation in debtor's handling of their commitment fee since debtor had, in fact, paid the money to the lender as he was instructed to do in the parties' contract. Judgment was entered in favor of debtor.

Chapter 13 debtors moved to disallow creditors' proof of claim, which listed their claim as secured. The court held that chapter 13 debtors do not have 11 U.S.C. § 544 "strong-arm powers," which may only be exercised by chapter 13 trustees. Allowing debtors to exercise such powers, absent a chapter 13 provision that specifically grants them to debtors, as does 11 U.S.C. § 1107(a) in chapter 11 cases, would do violence to the rules of statutory construction.

In her prepetition divorce action, debtor was awarded a $7,000 judgment against her ex-husband. Credit union, which held a judgment against debtor, obtained a garnishment judgment against debtor's ex-husband for the amount he owed to her. Debtor then filed a chapter 7 petition, in which she claimed the divorce award to be exempt. Postpetition, the state court reinstated credit union's garnishment judgment, which had previously been stayed, after ex-husband's appeal of the divorce award was denied. Debtor, who did not attempt to avoid credit union's lien on her divorce award, received a discharge in her bankruptcy. The court held that the garnishment lien survived debtor's bankruptcy, as it was still valid under the state court's prepetition stay order, which order allowed credit union to take action on the garnishment order after disposition of the appeal. However, the state court's postpetition reentry of the garnishment judgment violated the automatic stay, and was therefore void. The court held that credit union was free to enforce its lien, despite debtor's claim in bankruptcy that the divorce award was exempt, because 11 U.S.C. § 522(c)(2) permits enforcement of valid liens against exempt property. Debtor could still seek to avoid the lien under § 522(f), even post-discharge, but might be required to reimburse credit union's expenses as a condition of lien avoidance.