Standiferdl v. U.S. Trustee, No. 09-2238 (10th Cir. 2011)
Annotate this CaseThe debtors obtained confirmation of a Chapter 13 plan. The trustee sought dismissal because of their recalcitrance; they willfully failed to comply with an order requiring monthly reporting of income. The debtors converted to Chapter 7. The bankruptcy court denied discharge. The district court and Tenth Circuit affirmed. A Chapter 13 confirmation order is a lawful order of a court and pre-conversion misconduct justifies denial of discharge. The court interpreted a statutory reference to "the case" as referring to both the pre- and post- conversion proceedings.
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