Supreme Court of the United States
Hamilton, Chapter 13 Trustee v. Lanning
June 7, 2010560 U.S. 505
Summary
The Court held that a bankruptcy court calculating a debtor’s projected disposable income may account for changes in income or expenses that are known or virtually certain at confirmation. This forward-looking approach rejects a purely mechanical formula under §1325(b)(1). Justice Scalia dissented, arguing the statutory text mandates a mechanical calculation and does not permit adjustments for changed circumstances.
Holding
- Calculation of projected disposable income under §1325(b)(1). When a bankruptcy court calculates a debtor’s projected disposable income, the court may account for changes in the debtor’s income or expenses that are known or virtually certain at the time of confirmation.
Docket 08-998
Cited authorities
- 11 U.S.C. §§101
- 11 U.S.C. §1325
- 7 U.S.C. §1301
- 11 U.S.C. §1325
- 28 U.S.C. §586
- 11 U.S.C. §1325
- 119 Stat. 23
- 7 U.S.C. §1301