Summary:
In In re Dawson, the bankruptcy court faced a familiar but fact-intensive confirmation dispute over the value of a 1998 Fleetwood 76’x14’ manufactured home serving as the debtor's primary residence. Debtor Classie Dawson purchased the home in 2016 and sought to "cram down" the secured claim of 21st Mortgage Corporation—who holds a lien noted only on the certificate of title but did not file a UCC-1—to the asserted value of $4,890.