- Case Type:
- Consumer
- Case Status:
- Affirmed
- Citation:
- 24-1657 (3rd Circuit, Apr 17,2025) Not Published
- Tag(s):
-
- Ruling:
- Res Judicata prevents a chapter 13 debtor from relitigating the issue of post-judgment payments in the form of a claim objection under Pennsylvania law.
- Procedural context:
- Chapter 13 Debtor appeals the District Court’s order affirming the Bankruptcy Court’s overruling of his claim objection and denial of his subsequent motion for reconsideration on the basis of res judicata.
- Facts:
- The Pennsylvania Court of Common Pleas issued a consent order granting mortgagee an in rem judgment in the amount of $136,865.70, plus post-judgment interest. The Court of Common Pleas did not issue an opinion explaining its own calculation, but did state in its order that it had reached its conclusion “upon consideration of” mortgagee's motion.
The mortgagor subsequently filed a chapter 13 petition and eventually objected to the mortgagee's proof of claim on the basis that the reassessment order did not account for amounts he had allegedly paid following issuance of the consent judgment. The creditor countered that the Court of Common Pleas’ reassessment order controlled and that the doctrine of res judicata prevented the debtor from relitigating the issue of post-judgment payments before the Bankruptcy Court.
After an evidentiary hearing and supplemental briefing, the Bankruptcy Court overruled the claim objection on res judicata grounds.
The Third Circuit Court of Appeals affirmed, agreeing with the District Court and the Bankruptcy Court that, under Pennsylvania law, the issue is "actually litigated" for purposes of res judicata when it "is properly raised, by the pleadings or otherwise, and is submitted for determination, and is determined." (citations omitted).
"Although the brevity of the reassessment order precludes a full understanding of the Court of Common Pleas’ analysis, we are not persuaded that the Court lacked the authority to determine the issue of crediting post-judgment payments and therefore did not actually litigate the issue."
AFFIRMED
- Judge(s):
- Judges Thomas M. Hardiman & D. Brooks Smith
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