Doug Woods v. Chavon Marie Landingham

Summarized by Danielle Scott , U.S. Bankruptcy Court, Southern District of West Virginia
17 hours 51 min ago

Case Type:

Consumer

Case Status:

Affirmed in part and Reversed in part

Citation:

23-8018 (6th Circuit, Mar 17,2026) Not Published

Tag(s):

Ruling:

The Bankruptcy Appellate Panel of the Sixth Circuit affirmed in part, vacated in part, and remanded the case to the bankruptcy court for further proceedings. Specifically, the Panel affirmed the bankruptcy court's decision to deny Woods relief under 11 U.S.C. 523(a)(6), meaning it agreed that Woods failed to prove a willful and malicious injury sufficient to except the debt from discharge. The Panel also affirmed the bankruptcy court's denial of Woods's request for default judgment. The Panel then vacated and remanded the ruling on Woods's claims under 523(a)(2) and 727.

Procedural context:

This appeal arose from an adversary proceeding in Chavon Marie Landingham ("Debtor")'s Chapter 7 bankruptcy. Woods filed a complaint seeking to except his debt from discharge under 11 U.S.C. 523 and to deny Landingham's discharge under 11 U.S.C. 727, while Landingham later asserted counterclaims under Section 547 and 523(d). After trial, the bankruptcy court entered judgment in Landigham's favor on Woods's claims and granted relief on her counterclaims. Woods then appealed to the Bankruptcy Appellate Panel for the Sixth Circuit, which affirmed in part, vacated in part, and remanded for further proceeding.

Facts:

Doug Woods ("Woods") owned residential rental property in Ohio and leased that property to Chavon Marie Landigham ("Debtor") after initially denying her first rental application. The parties entered into a one-year lease from February 2018 and ending in January 2019. The Debtor remained on the property as a month-to-month tenant until she vacated the premises in May 2019. Following her departure, Woods alleged that the Debtor damaged the property by, among other things, striking the front porch with a baseball bat and pouring gasoline on the carpet. He also claimed that the Debtor made false verbal and written representations in connection with the rental application, including about her financial condition. Those representations allegedly induced him to approve the rental application. Woods later filed a small claims action in Ohio state court asserting breach of contract, fraud, and willfull/malicious property damage, obtained a judgment in the amount of $6,000.00 plus interest and costs when the Debtor did not contest the complaint. Garnishment began on the Debtor's wages, which led the Debtor to file a Chapter 7 petition on January 16, 2020. Woods commenced the adversary proceeding alleging that the debt owed to him was nondischargeable and that the Debtor concealed assets and failed to make disclosures in her bankruptcy filings.

Judge(s):

Bauknight, Gregg, and Mashburn

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