Shirley White-Lett v. RRA CP Opportunity Trust
- Summarized by Caleb Chaplain , U.S. Bankruptcy Court, Western District of Virginia
- 5 months 2 weeks ago
- Case Type:
- Consumer
- Case Status:
- Affirmed
- Citation:
- 24-13053 (11th Circuit, Sep 03,2025) Not Published
- Tag(s):
-
- Ruling:
- The Eleventh Circuit affirmed the district court’s order affirming the bankruptcy court’s dismissal of the debtor’s complaint objecting to a proof of claim. The Eleventh Circuit held that the debtor lacked Article III standing because she had no redressable injury, as there was no reasonable possibility that a successful claim objection would result in a surplus that would be returned to her from the bankruptcy estate.
- Procedural context:
- Shirley White-Lett, proceeding pro se, filed an adversary proceeding in her reopened chapter 7 bankruptcy case to object to a proof of claim filed by RRA CP Opportunity Trust 1. The bankruptcy court dismissed her complaint for lack of Article III standing, and the district court affirmed. White-Lett appealed to the Eleventh Circuit.
- Facts:
- In May 2005, White-Lett took out two loans totaling $715,500, each secured by her real property. The security deeds were later assigned to Bank of New York Mellon (BONY) for the first loan and to RRA for the second loan. White-Lett filed a chapter 7 petition in 2010, and she received a discharge in 2011. The case was closed in 2012. In 2020, the bankruptcy court reopened her case and set a deadline for filing proofs of claim. BONY filed a claim for $886,240.81 and RRA filed a claim for $83,226.17, both asserting their claims were secured by White-Lett’s residence. White-Lett challenged RRA’s claim, asserting her signature was forged and challenging the validity of the assignment. When the case was reopened, the trustee began investigating a potential $80,000 estate asset from proceeds White-Lett allegedly received from selling a business. The trustee agreed not to pursue recovery of this asset if White-Lett successfully disallowed both creditors’ claims.
- Judge(s):
- Jill Pryor, Lagoa, and Wilson
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