Hill v. Snyder, No. 17-3572 (8th Cir. 2019)Annotate this Case
After debtor sought Chapter 7 discharge, the trustee requested and received an extension to file a complaint objecting to the discharge after the trustee became aware of debtor's ties to business entities that were under a Florida receivership due to allegations of fraud. The Eighth Circuit affirmed the district court's decision affirming the bankruptcy court's order granting the trustee's request for an extension of time and its judgment denying discharge. The court held that the bankruptcy court did not abuse its discretion by extending the deadline for the trustee to object to the discharge under Rule 4004(b)(2) without an evidentiary hearing. In this case, there was no clear error in its determination that six days would be insufficient for the trustee to investigate further and compose allegations with sufficient particularity to satisfy the applicable pleading standard.