In Cournoyer v. Schamens (Bankr. M.D.N.C. Apr. 3, 2026), the Bankruptcy Court delivered a blunt reminder that discovery is not optional—even for pro se debtors. Faced with more than 400 days of noncompliance, repeated violations of court orders, and what it characterized as a pattern of bad faith and dilatory conduct, the court struck the debtor’s answer and entered default judgment denying discharge under 11 U.S.C. § 727(a)(2), (3), and (4).
Parrott v. Yeh is another chapter in the ongoing effort to unwind transactions tied to the collapse of entities associated with Greg Lindberg—this time through the lens of a Chapter 7 Trustee exercising core avoidance powers under the Bankruptcy Code.
The court denied the debtor’s motion for sanctions against the North Carolina DMV after her vehicle registration was revoked post-petition due to an insurance lapse. Why? Because the DMV wasn’t acting as a bill collector—it was acting as a regulator.
Two key takeaways drove the result:
No collection activity: The revocation wasn’t tied to collecting a prepetition debt. In fact, as of the petition date, there wasn’t even a matured “debt” to collect.
Arthur and Lisa Perry claim that a mystery deed of trust appeared in the public records against their home—one tied to a loan that Arthur Perry insists he never applied for, never authorized, and never received. According to the complaint, Mr. Perry purchased the property in 2005 with a legitimate mortgage, but in 2006 a second deed of trust was recorded in favor of Corinthian Mortgage (d/b/a SouthBanc Mortgage).
Judge Thomas Schroeder of the Middle District of North Carolina dismissed a borrower class action against Shellpoint Mortgage Servicing and the trust that owned the loan, holding that the plaintiffs’ North Carolina debt-collection and consumer-protection claims were simply an impermissible attempt to enforce the Truth in Lending Act (TILA) against parties that the statute largely shields from liability.
In re Bryant (I) — Strategic Disqualification Motions in § 523 Litigation
Summary
In the first January 2026 order, Judge Benjamin Kahn denied the pro se Chapter 7 debtors’ motion to disqualify the plaintiff’s counsel and stay proceedings in a nondischargeability action under § 523(a)(6).
Below is a practitioner-focused review of what can be gleaned from the Custer v. Dovenmuehle record you provided — not as a case summary, but as a toolbox for attacking mortgage Proofs of Claim in Chapter 13, both against Dovenmuehle and other servicers who use similar practices. I focus on what Custer alleged, what DMI admitted (or couldn’t), and how those themes translate into objections, discovery, and plan practice in consumer cases.
In Reid v. Rodriguez , the Bankruptcy Court for the Middle District of North Carolina dismissed, without prejudice, a pro se Chapter 7 debtor’s adversary proceeding against her landlord, holding that mandatory abstention under 28 U.S.C. § 1334(c)(2) applied—and that even if it did not, permissive abstention clearly would.
