2000 #29 Tidwell, 8-16-2000
IN RE: RONALD E. TIDWELL, CHAPTER 7; BANKR. NO. 98-50422
The matter before the Court is the Motion to Reopen Case filed by Holly Hayden on
August 8, 2000. This is a core proceeding under 28 U.S.C. § 157(b)(2). This letter
decision and accompanying order shall constitute the Court's findings and conclusions
under Fed.R.Bankr.P. 7052. As set forth below, the Court concludes that Hayden's Motion
must be denied.
Summary. Robert E. Tidwell ("Debtor') filed a Chapter 7 petition on July 31, 1998.
The last date to file a complaint objecting to the dischargeability of a debt under 11
U.S.C. § 523(a)(2), (4), (6), or (15) was November 2, 1998. Timely notice of the
case and the pending November 2, 1998 deadline was given to creditor Holly Hayden by the
Bankruptcy Clerk. On October 5, 1998, an order was entered granting Hayden's motion to
examine Debtor under Fed.R.Bankr.P. 2004. The November 2, 1998 deadline passed without any
dischargeability complaint being filed. Debtor received his discharge on November 3, 1998.
The case was closed as a no asset case on November 17, 1998.
On August 8, 2000, Hayden filed a motion asking the Court to reopen the case. In her
motion, Hayden stated she and Debtor had divorced in May 1996 and that as part of the
divorce agreement Debtor assumed responsibility to pay certain credit card debts and to
hold Hayden harmless therefore. In August 1997, Debtor was held in contempt by the divorce
court for failing to pay one of the credit card debts he had assumed. Eventually, the
divorce court ordered Debtor to sell a vehicle and apply $4,400 in proceeds on the credit
card debt, to apply his 1997 and 1998 income tax refunds toward this debt, to pay the
balance of the debt within 18 months of September 1997, and to get Hayden's name off the
account. At the time Debtor filed bankruptcy on July 31, 1998, the credit card debt was
still $7,500.
According to Hayden, after Debtor filed bankruptcy and after her counsel examined Debtor
under Rule 2004, she, Debtor, and their counsel agreed that Debtor would 'reaffirm' the
credit card debt. This oral agreement was made October 13, 1998, before the
November 2, 1998 dischargeability complaint deadline. However, a written agreement
was never signed.
The parties went back before the divorce court. On April 10, 2000, the divorce court again
held Debtor in contempt for failing to apply car sale proceeds and a tax refund to the
credit card debt. To purge himself from the contempt order, the divorce court allowed
Debtor to pay $300 per month on the debt until it was paid in full. Thereafter, Debtor
raised with the divorce court the issue that the credit card debt had been discharged in
bankruptcy and that Hayden could not maintain a contempt action in state court. Hayden
withdrew her contempt claim and the divorce court vacated its April 10, 2000 contempt
order.
According to Hayden, the credit card company is now looking to her for payment. She filed
this motion before the Bankruptcy Court asking it to reopen the bankruptcy case so that
(1) Debtor could be ordered to 'reaffirm' the credit card debt, (2) Hayden could be
reimbursed for payments she has or will make to the credit card company, and (3) Debtor
could be ordered to pay her attorneys' fees, sales tax, and costs.
Discussion. The time for entering an enforceable reaffirmation agreement has passed. See
11 U.S.C. § 524(c). The agreement would have had to have been memorialized before
November 2, 1998 to be enforceable. Since the parties do not have a reaffirmation
agreement that was signed before November 2, 1998, there is no need for this Court to
reopen the case to file an unenforceable reaffirmation agreement. Therefore, Hayden's
motion will be denied.
It appears that the real relief sought by Hayden is an order declaring the subject credit
card debt and companion hold harmless agreement non dischargeable. Under Local Bankr. R.
5010-1, a bankruptcy case does not need to be reopened to permit a party to file a
dischargeability complaint.
The Court notes that the time for filing a complaint under § 523(a)(15) has passed.
See 11 U.S.C. § 523(c) and Fed.R.Bankr.P. 4007(c). There is no deadline for filing a
complaint under § 523(a)(5). If Hayden intends to commence an action under
§ 523(a)(15), or under both § 523(a)(5) and (a)(15), the timeliness of her (a)(15)
complaint will have to be resolved first. This Court has not yet ruled on whether the
deadline established by Rule 4007(c) by can be extended for equitable reasons.
An order will be entered denying Hayden's motion without prejudice.