Bk Case Update

In Jacobsen v. Moser (In re Jacobsen), 609 F.3d 647 (5th Cir. 2010), the Fifth Circuit joined an increasing number of courts in holding Marrama v. Citizens Bank, 549 U.S. 365, 127 S. Ct. 1105, 116 L.Ed.2d 956 (2007) compels the conclusion that a chapter 13 debtor does not have an absolute right to dismiss a case where the debtor has acted in bad faith or abused the bankruptcy process and requested dismissal under §1307(b) in response to a request for conversion.