Christopher M. Cook v. Chapter 13 Trustee
Split Score
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This score (0-100) indicates how likely this case is to be reviewed by the Supreme Court based on:
Case Summary
Disposition
Reversed
The Fourth Circuit held that the district court erred in dismissing Christopher Cook’s Chapter 13 confirmation appeal as equitably moot because practical relief remained possible and the Mac Panel factors weighed against mootness. After reversing the district court, the court reached the merits and affirmed the bankruptcy court’s refusal to confirm Cook’s first proposed plan, finding no clear error in the determination that the plan lacked good faith.
Circuit Split Identified
Legal Issue
Proper standard of review (de novo vs. abuse-of-discretion) for a district court’s application of the equitable-mootness doctrine in bankruptcy appeals.
Circuit Positions
De novo review of equitable-mootness determinations
Abuse-of-discretion review of equitable-mootness determinations
Position not yet resolved / no definitive standard chosen
Conflict Summary
Most circuits review a district court’s equitable-mootness ruling de novo, whereas the Third Circuit applies abuse-of-discretion. The Fourth Circuit, in this opinion, again declines to choose a standard, leaving its position formally unresolved.