Summary

Judge Warren’s most recent opinion in In re Sugar (Bankr. E.D.N.C. Aug. 15, 2025) follows remand from both the U.S. District Court and the Fourth Circuit Court of Appeals. The case began with the dismissal of Christine Sugar’s Chapter 13 in 2023, coupled with a five-year nationwide bar on refiling, after she sold her residence without prior court approval in violation of E.D.N.C. Local Bankruptcy Rule 4002-1(g)(4).

Summary

McLaughlin’s bulletin provides North Carolina counties with a primer on tax foreclosure. Local governments can use either:

1. Mortgage-style foreclosure (G.S. 105-374) – a full civil action, with attorney’s fees chargeable to the taxpayer.

2. In rem foreclosure (G.S. 105-375) – a streamlined, judgment-based process with a capped $250 administrative fee.

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Available at:   https://scholarship.law.ufl.edu/facultypub/1234

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Available at:   https://www.responsiblelending.org/research-publication/shady-side-solar-system-financing

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Available at:   https://scholarship.law.stjohns.edu/bankruptcy_research_library/372/

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Available at: https://scholarship.law.stjohns.edu/bankruptcy_research_library/374/

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