Hamilton, Chapter 13 Trustee v. Lanning

Summary

The Supreme Court held that bankruptcy courts calculating a Chapter 13 debtor’s “projected disposable income” under 11 U.S.C. § 1325(b)(1)(B) may account for changes in the debtor’s income or expenses that are known or virtually certain at the time of confirmation. The Court rejected the mechanical approach of multiplying current monthly income by the number of months in the plan, favoring a forward-looking approach consistent with the ordinary meaning of “projected” and pre-BAPCPA practice. Justice Scalia dissented, arguing the statutory text requires a mechanical calculation based on historical data.