Chapter 13 Plan Must Pay Adequate Protection Payments Prior to Attorney’s Fees

In In re Dispirito, a decision of importance to Chapter 13 debtors’ attorneys, the Bankruptcy Court for the District of New Jersey ruled that an undersecured creditor was entitled not only to adequate protection payments, but that the section 507(b), 11 U.S.C. § 507(b) (2006), “super-priority” status of the inadequate adequate protection provided during the case meant that the Chapter 13 plan had to pay those amounts before paying any of the debtor’s attorneys fees.  371 B.R. 695, 695 (Bankr. D.N.J. 2007). This article will compare how the Dispirito court’s ruling compares to other bankruptcy court’s rulings. It will also analyze “super-priority” status in the context of benefits it confers to creditors and debtors and if it furthers bankruptcy law principles in general.

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Brian Lacoff, J.D. Candidate 2010
No. 17, Vol. 1 (2009)