In In re Peters, Judge Kahn addressed a recurring question: when Chapter 13 debtors propose to pay unsecured claims in full under §1325(b)(1)(A), must those creditors also receive post-petition interest?
In this unpublished October 15, 2025, decision, the Fourth Circuit affirmed the rulings of the Bankruptcy Court and the Eastern District of Virginia in a messy dispute arising from the dissolution of a small limousine company, All American Black Car Service, Inc. (“AABCS”). The case reads like a familiar tale of closely-held corporate dissolution gone awry—complete with COVID-era losses, unwritten understandings, and shareholder distrust—transposed into the bankruptcy context.
In Harrington v. Laney (COA24-1071, filed October 15, 2025), Chief Judge Dillon, joined by Judges Murry and Freeman, reversed a Superior Court verdict that had invalidated a deed executed under a power of attorney, holding instead that the plaintiff’s claims were barred by the statute of limitations.
